Impact assessment

Equality Analysis: In-Work Progression Offer

Published 17 April 2023

Introduction

This document records the analysis undertaken by the Department to enable Ministers to fulfil the requirements placed on them by the Public Sector Equality Duty (PSED) as set out in section 149 of the Equality Act 2010.

The PSED requires the Minister to pay due regard to the need to:

• eliminate unlawful discrimination, harassment and victimisation and other conduct prohibited by the Act.
• advance equality of opportunity between people who share a protected characteristic and those who do not; and
• foster good relations between people who share a protected characteristic and those who do not.

In undertaking the analysis that underpins this document, where applicable, the Department has also considered the United Nations Convention on the Rights of Persons with Disabilities (CRPD) and the United Nations Convention on the Rights of the Child (UNCRC)/ the United Nations Convention on the Elimination of all forms of Discrimination against Women (CEDAW).

A national Universal Credit (UC) In-Work Progression Offer

The support delivered in a Jobcentre Plus is primarily aimed at helping those who are unemployed to find work. Our intention is to implement a national offer of support for those who are in work, with low earnings, to help them progress.

The Policy at present

The original policy intent of UC is to not only support out of work claimants to move into employment, but also to support working claimants to progress and increase their earnings. The intensity of labour market support provided by Jobcentre Plus is primarily dependent on the earnings of the claimant and/or their partner and is defined by two thresholds.

1. The administrative earnings threshold (AET) is the lower threshold. It is set in regulations at an individual or household level. The AET ensures that claimants with no income or on a very low income receive the most intensive support.

2. The conditionality earnings threshold (CET) is a flexible threshold which is calculated based on the number of hours an individual claimant can reasonably be expected to undertake work or work-related activities based on their circumstances. In most cases, it is set at the rate equivalent to working 35 hours at the National Living Wage (NLW), but this can be adjusted to take account of health conditions or caring responsibilities.

Claimant or household earnings usually place working UC claimants (and their partners) in one of three labour market regimes:

• Intensive Work Search (IWS) regime - earning less than their AET
• Light Touch regime - earning at or above their AET but below their CET.
• Working Enough regime - earning above their CET.

Those in the IWS regime are required to accept a Claimant Commitment agreeing work search requirements and work availability requirements as well as Work Preparation and Work-Focused interview requirements ^{[footnote 1]}. They receive regular personalised support from a work coach.

People in the Light Touch regime can be required to attend Work Focussed Interviews and undertake Work Preparation activities. However, in practice, these claimants do not regularly interact with a work coach.

Claimants in the Working Enough regime have no conditionality requirements applied and do not receive routine work coach support.

The proposed changes

As announced at the 2021 Spending Review and the Levelling Up White Paper1 we are extending the support we provide in Jobcentres to include people in work and on low incomes in the Light Touch and Working Enough regimes.

All claimants in the Light Touch or Working Enough groups are eligible for a new voluntary support offer designed to help all working claimants to progress by providing individual and tailored progression support delivered by a work coach. This started to roll out from April 2022 and will be available across Great Britain by the end of March 2023. Eligible claimants will be contacted by their local Jobcentre to be offered progression support, if they choose.

To support our initiative, we are recruiting 37 District Progression Leads (DPL), one for each Jobcentre Plus district. The new DPLs will expand on the existing scope of Employer and Partnership teams with a more external focused lens towards promoting/aiding local employers and organisations to support low earners to progress in work and earn more.

The DPLs will have a key focus on collating and sharing data on local challenges, opportunities, and successes with the policy and strategy teams, with local operational leaders and with the national District Progression Lead network.

Autumn Statement Announcement

Claimants in the Light Touch conditionality group will start to have requirements placed on them to engage with the in-work progression offer. Attending Work Focussed Interviews and undertaking activities to increase their chances of progressing in work will become mandatory, in a phased approach starting from September 2023. The offer will remain voluntary for claimants in the Working Enough group.

The September 2023 start date will allow the department time to prepare for the change, including embedding the voluntary in-work offer and provide time to recruit and train the staff needed to deliver the new offer.

We already have the powers to introduce this offer for the claimants in scope, no legislation change is required.

Policy Rationale

Maximising employment and in-work progression is the first strategic objective in the DWP Departmental plan. Providing a comprehensive in-work support offer gives us an opportunity to:

• Strengthen our ability to tackle in-work poverty by helping claimants on low earnings address structural and motivational barriers, (confidence building, skills provision, help with childcare and transport costs), preventing claimants from being stuck in low pay.
• Make progression a key element of the government’s plans to tackle the cost-of-living challenge and high levels of inactivity.
• Support claimants towards medium term career goals and sector-switching options that could lead to better, more sustainable, and more productive jobs (rather than simply increasing hours in poor-quality work).

Progression is seen as a crucial factor in driving business success and economic recovery, underpinned by a common thread that supporting employees is the right thing to do. This was highlighted in an independent report^{[footnote 2]} published, on 1 July 2021, by the In-Work Progression Commission whose recommendations to Government and employers are to take action to help people to progress at work and move out of low paid employment.

The In-Work Progression Commission Report recommended that Jobcentres need to have an established, credible in-work offer for all working benefit claimants, to ensure that everyone, no matter their background, can have a fulfilling working life – one that allows them to progress in their chosen job/career or move into work which they find more rewarding with improved renumeration.

The need for this support is also evidenced by recent data on the national labour market. In 2022, around 3.1 million (10.5 percent) employee jobs were low paid (were paid less than two-thirds of median hourly pay), when considered in terms of hourly earnings. In 2022, (the same year), the UKs median hourly wage was £14.77 ^{[footnote 2]}.

What the changes will achieve

We want to drive-up engagement with UC claimants in the Light Touch and Working Enough groups to support them to stay in work, progress and earn more money. For most people, being in good appropriate work can be good for both physical and mental health as well as their social wellbeing. It will benefit employers and the economy through increased attendance and productivity in the workplace.

Based on emerging evidence, work coach support tailored to the individual need is effective at supporting working claimants and their families to remain and progress in work. In addition, our work coaches will provide a host of other support, including sign posting claimants to support services to help them overcome personal and work-based barriers.

We plan to support claimants to achieve a broad range of outcomes as we embed the progression offer into Jobcentres. These include:

• Increasing job quality, such as finding better work or more pay for the same work
• Increasing job stability, such as gaining a permanent contract /moving away from a zero-hour contract
• Entering an in-work development scheme, or an apprenticeship.
• Undertaking appropriate training
• Moving into a growth sector with better progression opportunities (such as a Green Job)

Our approach should allow us a better understanding of what activity is reasonable, what we can expect to achieve and with whom. This will provide a controlled and data-led basis to proceed without having a disproportionate impact on claimants with protected characteristics.

Impact on claimants and operations

Providing incentives and support for people to move into and progress in work is at the heart of UC. Claimants progressing in work can keep more of what they earn due to changes to the taper rate from 63 to 55 percent and a £500 increase to the work allowance which is the amount households with children or an adult with a disability or health condition which affects their capability for work can earn before their award starts to reduce. So, if this policy results in higher earnings for those affected, then the overall incomes of those households will raise, and those households will gain.

To support them to progress, claimants in the UC Light Touch and Working Enough groups will have access to work coach support in order to progress. This support could involve receiving support to up-skill or re-train, advice on job switching or using the Flexible Support Fund (FSF) to remove specific barriers to progression (subject to meeting eligibility criteria)

As of September 2023, some activities can be required as we introduce Work Focussed Interviews (WFI’s) and Work Preparation requirements with some claimants in the Light Touch conditionality group.

These conditionality requirements could include:

• Work Focussed Interview - claimants would be required to attend and participate in interviews with their work coach.
• Work Preparation – activities could include attending a skills assessment or creating a CV.

The activities will be set out in the Claimant Commitment, which clarifies both what is expected in return for benefits and support, and exactly what happens if they fail to comply.

Claimants who fail to comply with requirements in their Claimant Commitment without good reason may be sanctioned.

Any expectations, such as attending appointments with a work coach or undertaking activities to support progression, will be reasonable and tailored to a claimants’ circumstances, mirroring the treatment of out of work claimants. It will be made clear through internal communications that no activity should interfere with a claimants’ current work commitments. Work coaches will be issued with clear guidance around setting appropriate requirements for in-work claimants.

Claimants in the Working Enough group can volunteer to undertake any work-related activity depending on their circumstances, but any failure will not result in a reduction of payment.

For the voluntary offer, work coaches can engage with their claimants using the following channels:

• In person at their local Jobcentre
• By Video
• By Telephone

The use of multi-channel appointments provides greater flexibility to claimants who are working or have caring commitments. We are currently designing the approach for the mandatory offer that will start from September 2023.

To effectively embed the cultural and behavioural change required to support working claimants we will deliver tailored learning and development sessions to work coaches which will be iterated based on feedback as the policy rolls out.

This policy aims to support individuals of all genders and ethnicities regardless of protected characteristics and data analysis has been conducted to examine whether those with certain protected characteristics may disproportionately benefit or lose out.

Evidence and Analysis

The main source of evidence on whether Jobcentre Plus (JCP) can support working claimants to increase their earnings and progress is taken from the Randomised Control Trial (RCT) ^{[footnote 3]} conducted by DWP between 2015 and 2018. The trial involved UC claimants with low earnings in the newly formed Light Touch conditionality group. The trial was designed to test the impact on earnings of conditionality – including the potential for sanctions - with different frequencies of support provided by Work Coaches. The results of this trial are publicly available.

In headline terms, the RCT delivered average earnings increases of £4.43 and £5.25 a week after 52 weeks for participants in the Moderate (8-weekly interventions) and Frequent (fortnightly interventions) support groups.

A longitudinal study conducted by Ipsos MORI also looked at the extent to which the support provided had helped participants to build a foundation for long-term progression. Overall, there were some encouraging findings for participants, particularly for those in the Frequent Support group, even if these did not translate into earnings outcomes during the trial.

The research found that the number of claimants in permanent work increased by 5 and 6 percentage points in the Moderate and Frequent groups over the course of the trial, compared to no improvement for those with Minimal support. This matters because the research also found that employers were significantly more likely to support permanent members of staff to progress than those on a temporary or zero-hours contract.

Among participants, a large majority (91 percent) had undertaken a number of actions to progress in work, most commonly looking for a new job (in place of or alongside their existing job) and requesting additional hours from their employers. The number of actions taken was consistent across the groups, although there were differences in relation to specific actions. For example, Frequent Support participants were more likely than other participants to have been on a training course to improve their qualifications or skills (33 percent, compared to 24 percent for the Moderate Support group and 26 percent for the Minimal Support group). They were also more likely than other groups to report that the actions that they had undertaken had resulted in a new job (22 percent, compared to 16 percent for the other two groups) or increased hours (45 percent compared to 37 percent for the Moderate Support group and 33 percent for the Minimal Support group).

To inform the IWP SR bid and the design of our new offer, a JCP led progression Proof of Concept (PoC) started in Jobcentres across South Yorkshire in 2021 and concluded in March 2022. The PoC demonstrated that overall, it is possible for the JCP to deliver the IWP offer successfully, while at the same time important lessons were identified for future roll-out. The offer had a range of positive impacts, from building awareness of support available to participants changing their job or increasing their earnings.

In addition, we are currently running a PoC which was developed in partnership with Tameside Metropolitan Borough Council (MBC) and the Greater Manchester Combined Authority (GMCA) which started in January 2022. The key elements of the PoC are:

• Testing the process of cross-agency working for the purpose of supporting progression.
• Testing alternative of delivering progression support and integrating provision to provide a more holistic package for participants.

Analysis of impacts

Based on the findings of the in-work progression RCT, we expect that this change will have a positive impact on claimants’ earnings, through the provision of regular and tailored work coach support.

Work coaches must be compliant with The Public Sector Equality Duty (PSED) eLearning course (having obtained a minimum pass mark of 80 percent) to enable them to understand the need to consider the effect our policies and practices have on equality. This is subject to refresher training at least every 3 years.

When conditionality is applied to claimants in the Light Touch conditionality group they will have to undertake certain work-related activities, depending on their circumstances, and will be subject to a referral to the Decision Makers which could potentially lead to a sanction if they do not comply with these requirements without good reason.

Analysis of DWP administrative data taken during the Randomised Control Trial found that overall, 2.4 percent of trial participants received a sanction. The Frequent Support group had the highest sanction rate at 3.1 percent, compared to 2.6 percent for the Moderate Support group and 1.5 percent for the Minimal Support group. Failure to attend an interview with a Work Coach was the most common reason for being sanctioned. This accounted for 91.2 percent of sanctions applied. Consequently, most sanctions applied (91.6 percent) were low-level sanctions.

For more recent context, the overall current UC sanction rate is 6.37 percent ^{[footnote 4]}. We are not able to distinguish the sanction rate between those who are not working at all, compared to those who are working some hours.

The impact of IWP participation on claimants with protected characteristics are addressed below.

Age  

Table 1 shows the age breakdown of UC Light Touch and Working Enough.

Table 1 ^{[footnote 5]}

Age group:	Light Touch & Working Enough (percent)	Light Touch (percent)	Working Enough (percent)
16-24	4.5	3.8	4.9
25-49	80.7	72.9	85.7
50+	14.7	23.1	9.4
Unknown/Missing	0.1	0.1	0
Total	100	100	100

Column totals may not add up to 100 percent due to rounding.

Given the relatively high proportion of 25-49-year-olds in these two groups, the policy may benefit these claimants in greater numbers than claimants in the other age groups but that is simply a reflection of the make-up of these groups. Claimants of all ages in the light touch and working enough groups will benefit in the same way.

Work coaches delivering IWP will be able to liaise with Youth Employment Coaches (YEC’s) and 50+ Champions for additional specialist advice and support

Table 2 below provides the age breakdowns of UK working age population, total UC caseload and the latest UC sanction rates.

Table 2

	UK working age population (Mid-2022 percent)	Total UC caseload (UC Aug 22 percent)	UC sanction rate (UC Aug-22 percent)	Of all sanctioned, percentage contributed by each age group (UC Aug 22 percent)
16-24	16.9	12.5	12.2	32.7
25-49	52.1	64.7	6	57.9
50+	31	22.7	2.8	9.4
Total	100	100	6.4	100

Column totals may not add up to 100 percent due to rounding.

UK working age population^{[footnote 6]}. Total UC caseload^{[footnote 7]}. UC sanction rate^{[footnote 8]}. Of all sanctioned, percentage contributed by each age group^{[footnote 8]}.

In the table above, 16–24-year-olds are the smallest group in the total UC caseload and the working-age population, whereas 25–49-year-olds are the largest group.

Table 2 also reports sanction rates. UC sanctions data shows that 16-24-year-olds receive more sanctions when compared to their proportions in the UC caseload and the working-age population. In contrast, claimants aged 50 years and older receive fewer sanctions.

Disability

In UC those with an accepted health condition are likely to be placed in a number of different conditionality regimes e.g., those with a current fit note will largely be in the Intensive Work Search Group, and those found to have Limited Capability for Work and/or Limited Capability for Work Related Activity after their Work Capability Assessment (WCA) are placed in the Work Preparation and No Work-Related Requirements groups respectively.

Table 3 below provides proportions of claimants in the Light Touch and Working Enough claimants, who have declared a health condition and are awaiting a WCA.

Table 3 ^{[footnote 9]}

Light Touch & Working Enough (percent)	Light Touch (percent)	Working Enough (percent)
1.1	1.6	0.9

In line with the general approach in UC, claimants with health conditions will be offered support on a voluntary basis in the first instance.

Work coaches delivering IWP to claimants with a health condition / disability will be able to consult Disability Employment Advisers (DEA’s) to ensure appropriate comprehensive support is being offered.

Gender reassignment

We have no evidence or reason to suggest that this change will disproportionately affect anyone with the protected characteristic of gender reassignment. Data is not available on gender reassignment for Universal Credit claimants.

Marriage and civil partnership

We have no evidence or reason to suggest that this change will disproportionately affect anyone based on the protected characteristic of their marriage or civil partnership. Data is not available on marriage and civil partnership for Universal Credit claimants.

Table 4 below provides proportions of current Light Touch and Working Enough claimants in single and couple contracts.

Table 4^{[footnote 10]}

	Light Touch & Working Enough (percent)	Light Touch (percent)	Working Enough (percent)
Single	50.9	52.4	50.0
Couple	49.1	47.6	50.0
Total	100.0	100.0	100.0

Column totals may not add up to 100 percent due to rounding. Current data is unable to link this to marriage and/or civil partnership.

Pregnancy and maternity

We have no evidence or reason to suspect that this change will disproportionately affect anyone with the protected characteristic of pregnancy or maternity.

Table 5 below provides proportions of parents and lone-parents in Light Touch and Working Enough groups.

Table 5^{[footnote 10]}

	Light Touch & Working Enough (percent)	Light Touch (percent)	Working Enough (percent)
Non-parents	16.4	28.9	8.5
Parents	83.6	71.1	91.5
Total	100	100	100
Of this total, percentage who are Lone Parents	38.8	30.8	43.9

Column totals may not add up to 100 percent due to rounding.

Within the Light Touch and Working Enough groups 83.6 percent are parents and 38.8 percent are lone parents. It is worth noting that for claimants with young children, interviews must be arranged taking childcare availability into account. Impacted claimants should also be made aware that they can re-arrange interviews if they have a good reason for why they cannot attend, for example, rescheduling appointments around childcare, social services, or medical appointments.

A lead carer with a child under one year old falls into the No Work Related Requirements regime and is not subject to conditionality.

Race

We have no evidence or reason to suspect that this change will disproportionately affect anyone based on their race. The ethnicity breakdown of the UK working age population is provided in Table 6 below.

Table 6 ^{[footnote 11]}

	UK working age population (percent)
White	84.5
Asian	5.9
Black	3.6
Mixed	1.7
Other	4.2
Total	100.0

Column totals may not add up to 100 percent due to rounding.

The level of non-completion of the voluntary Equality Survey in the claimant UC portal represents both the level of uncertainty around the figures and means the likelihood of responder bias is more prominent. The effect of responder bias could be quite substantial, yet unquantifiable. Therefore, any attempt to infer meaning from these figures would likely be misleading. Consequently, no information on the ethnicity of UC claimants will be released. This information would not be meaningful until the completion rate is at 70 percent or above. Work is on-going to improve the completion rate. Everyone in light touch or working enough, irrespective of their race, will benefit and be impacted in the same way.

Religion or belief

We have no evidence or reason to suspect that this change will disproportionately affect anyone based on their religion or belief. Data is not available on religion or belief for Universal Credit claimants.

Sexual orientation

We have no evidence or reason to suspect that this change will disproportionately affect anyone based on their sexual orientation. Data is not available on sexual orientation for Universal Credit claimants. ###Sex

Table 7 provides the age breakdowns for UC Light Touch and Working Enough groups.

Table 7 ^{[footnote 11]}

	Light Touch & Working Enough (percent)	Light Touch (percent)	Working Enough (percent)
Male	36.8	35.9	37.4
Female	62.9	63.7	62.5
Unknown/Missing	0.2	0.4	0.1
Total	100.0	100.0	100.0

Column totals may not add up to 100 percent due to rounding.

Given the relatively high proportion of women in these groups, the policy may benefit women in greater numbers but that is simply a reflection of the makeup of the groups and everyone in the Light Touch and Working Enough groups will benefit in the same way.

Table 8 shows the gender breakdowns of UK working age population, total UC caseload and UC sanction rates.

Table 8

	UK working age population (Mid-2020 percent)	Total UC caseload (UC Aug-22 percent)	UC sanction rate (UC Aug-22 percent)	Percent total UC sanctioned (UC Aug-22)
Male	49.9	43.2	9.5	76.6
Female	50.1	56.8	3.1	23.4
Total	100	100	6.4	100

UK working age population^{[footnote 12]}. Total UC caseload^{[footnote 13]}. UC sanction rate^{[footnote 14]}. Percent total UC sanctioned^{[footnote 14]}.

Compared to the UK working-age population, women make up a disproportionate share of the UC caseload (56.8 percent compared to 50.1 percent).

Table 8 also reports sanction rate. UC data shows that male claimants have a higher sanction rate than expected from looking at their proportion in the UC caseload and the working-age population.

Decision making

  Our aim is to proceed as planned with the proposal. The policy has no direct impact on any group with protected characteristics, however there may be some indirect impacts depending on the make-up of the claimants in the Light Touch or Working Enough conditionality groups at the time. Any indirect impacts will be positive and beneficial as this change is intended to be non-punitive.       The impacts outlined above are based on our assumptions of what we will deliver over the full Spending Review (SR) period (2022-2025)   We will update and review these impacts on an ongoing basis, to ensure they reflect the latest policy position.      Learning from evidence and applying good practice from the roll-out will be refined and carried forward to the policy design in Year 3, to ensure the national policy is inclusive for the increased volumes of customers with protected characteristics.

Where possible, we will take into consideration advice and look at the best practice guides of organisations who represent females, parents and those who have limited capability for full time work and incorporate their advice into the policy design, where appropriate. This will help ensure that the methods the department develops to enable customers to progress in work, meet their needs. Incorporating customer needs at the design stage will help mitigate adverse impact and increase the level of engagement from the groups of customers we are aiming to support.   

Monitoring and evaluation

The policy and the impacts, including continuous improvements as set out in this assessment will be reviewed during design and implementation stages.       Positive measures to reduce or remove negative impact on those with protected characteristics, that may subsequently emerge, will be built into the design of the In-Work Progression Offer.      As the policy develops the PSED will be reviewed and updated regularly to reflect progress.     

Sign off

  

Name of person who carried out this analysis: [Redacted], [Redacted]  

Date analysis completed: 20/12/2022
 

Name of Senior Responsible:  

[Redacted], Deputy Director for Employment, Youth and Skills.

[Redacted] (deputising for [Redacted], Deputy Director, Labour Market Analysis)

[Redacted], Senior UC Lawyer   

Date assessment was signed: 16/02/2022

1. Universal Credit: Your responsibilities - GOV.UK (www.gov.uk) ↩

2. Low and high pay in the UK - Office for National Statistics (ons.gov.uk) ↩ ↩²

3. Universal Credit: in-work progression randomised controlled trial - GOV.UK (www.gov.uk) ↩

4. Benefit sanctions statistics, November 2022 ↩

5. Analysis of internal UC data, June 2022. ↩

6. Analysis of population estimates tool for UK, Office for National Statistics, 2021. ↩

7. People on UC, Stat-Xplore. ↩

8. Analysis of UC Sanction Rates, Stat-Xplore. ↩ ↩²

9. Analysis of internal UC data, June 2022. ↩

10. Analysis of internal UC data, June 2022. ↩ ↩²

11. Annual Population Survey (APS), 2022, Nomis. ↩ ↩²

12. Analysis of population estimates tool for UK, Office for National Statistics, 2021. ↩

13. People on UC, Stat-Xplore. ↩

14. Analysis of UC Sanction Rates, Stat-Xplore. ↩ ↩²