Response: SSAC universal credit consultation

By: Kate Webb  Published: August 2012

Shelter welcomes the opportunity to comment on the Universal Credit draft regulations. The Welfare Reform Act is a skeletal act and we were concerned that some areas of policy detail were not sufficiently developed to allow adequate scrutiny during the parliamentary process. We therefore are pleased that SSAC is now scrutinising the regulations.


Our response focuses on the areas which SSAC has indicated are of particular interest and highlights a number of additional changes which are of concern to us. This is not a comprehensive list but reflects the areas we think should be prioritised for revision.

Key recommendations
  • SMI payments to be based on claimant's actual interest rate, subject to a reasonable cap.
  • SMI waiting period to be retained at 13 weeks under Universal Credit.
  • Telephone and face to face applications to be retained until digital inclusion is fully achieved.
  • The Department for Work and Pensions works urgently with the banking sector to ensure adequate financial products are available to support direct payments.
  • Households working “mini jobs” should be exempted from the benefit cap.
  • Households in temporary accommodation should be exempted from the benefit cap or the cost of TA excluded.
  • Existing 13 and 52 week protection rules for households should be retained.
  • Households facing an unavoidable delay in moving into a new home or threats of violence or abuse should be entitled to housing cost support for two properties for a limited period.
  • Under 25s on JSA or ESA should be exempted from a housing cost contribution.


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