My Lords, I agree with the noble Baroness, Lady Sherlock, on her analysis of the changes that have been made. Some are very welcome, but we are still facing a major, dramatic piece of administrative change. It will severely affect vulnerable families who are on low legacy benefits at the moment. I do not think it is safe to do this without somehow making an attempt to get an impact assessment of what the long-term effects will be. This legislation was originally put in place in the Welfare Reform Act 2012. A lot of water has flowed under the bridge since then. We now have some very detailed and complicated regulations. Before we start the process, it would be good to know what the department expects the outcome to be. If we cannot get that, we will to a large extent be flying in the dark.
I welcome the three-month grace period for the minimum statutory notice period for the benefit, but we still have a hard stop at the end of that. Three months is better than one month, but can the Minister explain the sentence in the Secretary of State’s Statement which deals with the one-month period becoming three months? It says that,
“we have unlimited flexibility to extend claim periods for people who need it”.
Can she say what the circumstances are in which someone could claim to need that? Unlimited flexibility could mean that people were not facing a hard stop for legacy benefits, so it would be very useful to understand better what that sentence actually means.
I agree with the noble Baroness, Lady Sherlock, and with the Social Security Advisory Committee, that it would be much safer to try and segment some of the clients we are approaching in managed migration to identify vulnerable people. I do not mean vulnerable only in terms of disability and so on, but also in terms of heavy indebtedness, which means that they are unlikely to be able to withstand a long—or indeed any—gap in benefit provision during transition. We know that data is available, because organisations such as Policy in Practice are already stitching together local authority housing benefit data with Treasury, HMRC and DWP data. There is enough material there to anticipate the households that will have real difficulty facing this. I understand the department is saying that the systems do not talk to one another. During the managed migration period, which admittedly does not start for some time yet, we will not, as I understand it, have the advantage of an ability to mash that data and identify vulnerable groups. It can be done by think tanks and research groups; I think it should be done by the department. Proposals to differentiate the impact on different groups of people is, I believe, very important.
Another thing, from a logistics point of view, is that I understand we have to get these regulations done and dusted by the end of the calendar year. The Minister is very good at offering briefing sessions before these regulations hit the Floor; they are affirmative regulations and will need to come to the Floor of the House. I understand the urgency of getting the legality put in place to cover the department for the trial period—the test and learn period—early next year. I plead with the Minister to give us enough time collectively in this House to understand the full significance of all these changes. Some are beneficial, but we are still facing an enormous difficulty that could have a dramatic impact on low-income families in future.