Consultation outcome

The Royal British Legion response

Updated 23 March 2020

1. About Us

The Royal British Legion is at the heart of a national network that supports our Armed Forces community through thick and thin – ensuring that their unique contribution is never forgotten. We were created as a unifying force for the military charity sector at the end of the First World War, and still remain one of the UK’s largest membership organisations. The Legion is the largest welfare provider in the Armed Forces charity sector, helping veterans young and old transition into civilian life. We help with employment, financial issues, respite and recovery, through to lifelong care and independent living. For further information, please visit the British Legion website

The Legion was formed in 1921 to care for those who had suffered as a result of the Great War. There was a strong emphasis on issues such as pensions and employment in this period and engaging with government and public bodies has been essential to improving the lives of service personnel and their families ever since.

The Legion provides support to relieve immediate financial hardship, through grants for housing, food and utilities and working with beneficiaries to prevent long term deprivation through personalised support packages and access to a specialist Benefit, Debt and Money Advice Service. The Legion also assists with War Disablement Pensions and Armed Forces Compensation Scheme Appeals.The Legion provides Outreach Service which supports vulnerable beneficiaries to access services such as housing, mental health and addiction services.

2. General Comments

Engagement with the Department of Work and Pensions (DWP) is essential to the Legion’s work in improving veterans’ experiences and access to benefits. The Legion values engagement with the DWP and is grateful for the opportunity to provide feedback on the effectiveness of this engagement.

The Legion has had successful engagement with the DWP, working recently to improve Personal Independence Payment assessors’ knowledge of Post-Traumatic Stress Disorder by contributing to Condition Insight Reports.

3. Process of Engagement with the DWP

The Legion engages with the Department in two main ways: through consultation responses; and by attending engagement events, forums and workshops. The Legion responds to consultations when we believe they are relevant to the Armed Forces community, and where departmental policy may raise an issue that uniquely or disproportionally affect this group.

An example of good practice was the engagement approach adopted for the Work, Health and Disability Paper: Improving Lives 2017 Green Paper on Health and Disability, which the Legion participated in. Whilst the paper was under consultation, the Legion attended an Armed Forces stakeholder engagement event held by the DWP, providing us with an opportunity to provide feedback on the ideas presented in the paper. We would encourage the increased use of specific Armed Forces stakeholder events and focus groups, especially when discussing topics which may have a Service specific angle such as the provision of benefits linked to a Service-related condition.

In addition to engaging with consultations through focus groups and providing written submissions, our engagement with the department has been through DWP events and forums or through meetings held with individual civil servants. This engagement has been mainly through formal and informal interactions with other third sector colleagues and DWP staff.

In our experience, informal discussions on policy areas have arisen as a result of conversations at events with DWP staff, or via engagement with other third sector colleagues. Whilst these have proved useful and we are encouraged by the collaborative nature of the engagement, they rely on existing engagement and networks and as such should be viewed as a welcome supplement to formal channels and initiatives.

Formal engagement the Legion has been party to has arisen through invitations from the Department to stakeholder meetings or forums, or via membership of sectoral groups such as the Disability Benefits Consortium. The majority of engagement events the Legion attends do not require specific information in advance of attendance or in response to the invitation. However, the Operational Stakeholder Engagement Forum (OSEF), which is run quarterly, requires information on organisation size, how information from the forum would be distributed, the attendee’s role in the organisation and their interest in the topics under discussion.

In terms of feedback provided to the DWP, feedback forms are circulated and returned. From the Legion’s experience, some of the feedback provided has been taken on board and discussed at the next meeting of the forum. Examples of the feedback provided ranges from practical issues such as accessibility of the facilities to suggestions for topics to be discussed.

Response to the feedback has varied, issues around accessibility can (in most cases) be easily rectified, however feedback on larger more structural issues such as disability benefit assessments, often do not translate into tangible improvement of service delivery. Whilst we understand that larger scale changes cannot be implemented in an equally straightforward manner, there is scope to improve the mechanism to provide a more transparent feedback loop, with all issues raised noted and responded to in a clear and timely manner.

The Legion has found that interaction with the Department is targeted a wide range of stakeholder practitioners, who are enthusiastic about engaging. This, in some forums means that the unique impact of policy on veterans can easily be lost.

As Members of the Armed Forces and their families are noted as a vulnerable group in the DWP’s Vulnerability Guidance, this should allow for specialised engagement by the Department with this group. We would welcome the establishment of an Armed Forces forum or sub group to existing forums to explore in detail specific issues such as benefits and compensation. This engagement would benefit the Department, if veterans who have experience of the system are included. It would also signal to service users that they are being listened to.

4. Benefits of Engaging with the DWP

Engagement with the DWP has had some clear benefits for the Legion’s beneficiaries. It has provided an opportunity to clearly understand policies and the intent behind policy and process, allowing the Legion to more effectively raise concerns or provide feedback where there is an inadvertent impact on the Armed Forces community. We are able to ensure that the voice of this community is heard and can influence the delivery or operation of policy. For example, the Legion has provided feedback on the design of information literature specifically for those transitioning from Service and who may need to claim Universal Credit.

Engaging with the Department, whether at specific Armed Forces community focussed events or general events on disability, is valuable. DWP-facilitated networks provide opportunities to meet and collaborate with other organisations which, in turn, allows for the building of relationships with those who are working in similar areas and facilitates the sharing of best practice within the charitable and statutory sector.

However, as noted above, repeated engagement around topics is not always effective, particularly around structural and policy issues. For example, multiple stakeholders consistently raise improving assessments for disability benefits yet there is a lack of feedback mechanisms in place for addressing these concerns, leaving stakeholders unaware of the impact or outcome of raising their concerns.

Engagement, and a continued willingness to engage, can only be successful if it is transparent and candid. If there are specific reasons why issues consistently raised are not addressed, it is important to know the reasoning or barriers. An improved feedback loop within forums is therefore required, which would allow the Legion to engage further in a productive manner, setting the parameters for engagement and being able to focus resources on areas where we are able to influence change.

Whilst improvements to assessments have not always happened at a pace the Legion would have preferred, it must be noted that the Department have kept us abreast of plans to reform the Work Capability Assessment. The Legion has attended an initial workshop on assessment reform. However, other workshops held by other teams in the Department working on reform have been held and the Legion has only found out about these through word of mouth.

5. Improvement to Engagement

One area where improvements can be made to engagement is coordination and logistics between DWP teams, contracted suppliers within the benefits system and working groups, especially around the planning of engagement events.

Often, workshops and events of interest occur in the same week and at the same location. This sometimes requires a large expenditure of both time and funds for practitioners, with valuable insight who wish to take part. The Legion has 15 area offices around the country and specialist advisers in each who would benefit from attending forums and events locally. This would also benefit smaller, under resourced organisations around the country. The current approach to engagement means that stakeholder representatives can be left needing to prioritise engagement or may miss out on opportunities to provide the department with critical feedback and insight. The Legion recommends that further internal coordination happen within the DWP and their contracted welfare providers to produce an engagement timetable where clashes are minimised.

Engagement can be significantly improved by focusing more on policy issues. Many of the stakeholder events attended by the Legion have focussed on operational activity, for instance one workshop attended included a demonstration of Alternative Payment Arrangements for rent in Universal Credit. This was an interesting demonstration; however, the Legion was concerned with how the criteria for requesting an alternative payment was developed. This could not be explained as the presentation was given by a member of DWP staff who designed the IT process and did not have strong knowledge of the policy behind the process. The session could have been significantly enhanced by the inclusion of a policy specialist who could explain the criteria in detail.

As repeated elsewhere in this submission, for engagement to be effective there needs to be a more comprehensive feedback loop. Often new initiatives are presented at meetings such as new teams and processes, but there is no reporting on how effective these initiatives have been or how they came about. Forums could also benefit from the department feeding back to the forum on issues that have previously been raised.

As noted above, the Legion would like to see a specific Armed Forces forum to discuss the issues around disability that affect veterans and their families. This forum should include veterans as this approach could work positively for the DWP. It would provide a space for the Department to explain benefits processes, the intent behind policies and procedures and provide an opportunity to manage expectations. It may also mean that the veteran’s experience of claiming benefits is improved as the DWP may be seen to be engaging them.

6. Engagement with Other Public Sector Bodies

The Legion has frequent engagement with the Ministry of Defence on specific Armed Forces disability issues through forums focussing on Wounded, Injured and Sick (WIS) veterans and on Armed Forces compensation. These groups focus largely on disability in the Armed Forces and the support they will require or are able to receive once medically discharged or no longer serving. We also engage with the Department of Health and Social Care on veterans’ health and care, specifically mental health services.

As with engagement with the DWP, the Legion has been involved at different points with services and policies. As the Legion has significant experience of supporting the Armed Forces community, we welcome opportunities to be included in initial meetings and at the design stage of an intended service or policy. At this stage, we are able to offer insight and expertise and ensure that the beneficiary voice is included throughout the policy process. This has happened frequently with NHS mental health services and Public Health England.

The Legion would also welcome further exploration of steering group models for user involvement and engagement. The Ministry of Defence runs a Service Charities Partnership Board, consisting of senior leaders of major Armed Forces sector charities, enabling them to co-ordinate and steer progress on policy issues. On a working level, the Armed Forces compensation chamber provide a steering group model, chaired by the chairman of the Confederation of Service Charities, constituting both public and third sector policy and practice leads, and hosted by the Courts and Tribunal Service, the steering group provides a critical friend and oversight role to the operation of the chamber. The Legion would welcome further exploration of the use of cross sector and independent steering groups.

7. Other Comments

The Legion would welcome more consistent engagement with the DWP. One way of implementing this would be to follow up with all organisations and individuals who submitted consultation responses on individual policy initiatives, inviting them to stakeholder engagement events regarding the consultation. This would create a starting point for a process of engagement and would also provide a wide range of stakeholders; from large organisations to individuals who are able to provide lived experience.

From the Legion’s experience, we believe that more could be done to ensure that veterans are consulted on policies and operational process directly. Written consultation responses may not be a practical way for individuals to engage with policy development, however other methods of engagement should be explored. Lived experience contributions in focus group run by the Legion have been invaluable in our research into the needs of the community and informed our engagement with the DWP. Whilst working on the Ministry of Defence’s Strategy for Our Veterans in 2019, the Legion held focus groups around the country with veterans of all ages. The groups provided strong anecdotal evidence for the response and shed light on aspects of the veterans’ experience that were not well known, especially with regards to interactions between disability benefits and Armed Forces compensation schemes. Further use of focus groups within this demographic by DWP would be welcome and the Legion would welcome the opportunity to work with DWP officials on facilitating them.

8. Conclusion

The Legion values the engagement with the Department of Work and Pensions and believes that it is integral to the making sure that veterans are able to access welfare benefits reliably and with as little stress and anxiety as possible. To make engagement more effective for the whole Armed Forces community, specific forums where all issues affecting veterans, serving personnel and their families claiming welfare benefits can be discussed should be organised. The veterans’ community is not homogenous, and their needs will vary dependent on their age, the compensation they receive and the needs of their families and dependents.

Lastly, engagement with the Department must result in serious consideration of the issues raised and where necessary, should result in structural improvement, for example, changes to disability benefit assessments. This is crucial to keeping stakeholders involved and motivated in improving the services the Department provides.

9. Recommendations

• We would welcome the establishment of an Armed Forces forum or sub group to existing forums to explore in detail specific issues such as benefits and compensation.

• The Legion recommends that further internal coordination happen within the DWP and their contracted welfare providers to produce an engagement timetable where clashes are minimised.

• The Legion would welcome further exploration of the use of cross sector and independent steering groups.

• Further use of focus groups within this demographic by DWP would be welcome and the Legion would welcome the opportunity to work with DWP officials on facilitating them.

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March 2020