Cumulative Impact Assessment (CIA)

Author: Simon Duffy

In 2010 the Coalition Government introduced the most radical changes to the UK welfare state since its creation. Deep cuts in services were combined with major changes to the benefit system. It was obvious to any neutral observer that there would be significant consequences for many disadvantaged groups, particularly disabled people. 

The UK Government is a signatory to the UN Convention on the Rights of Persons with Disabilities (UNCRPD), as well as other important human rights treaties. So it has not just a moral duty, but also a duty in international law, to take the human rights of persons with disabilities seriously. It should endeavour to improve the position of disabled people in society, and it should certainly not worsen their position. 

A Cumulative Impact Assessment (CIA) is an evaluation of the combined impact of different government policies. Given the wide-ranging nature of the Government's Austerity plans it would be natural to suppose that any government that meant to honour its duties to disabled people would carry out a CIA to ensure that it was not exposing people to harm by the combined impact of its policies. However, despite the calls of disability campaigners (at first Pat's petition and then the WOW Campaign), of many charities and of multiple United Nations human rights bodies, the Government has refused to carry out a CIA.

More than this, the Government has continued to make the utterly self-contradictory claim that it cannot carry out a CIA, but that its policies will have a beneficial impact on disabled people. How would it know?

Since 2011 the Centre for Welfare Reform has published a series of progressively more sophisticated CIAs and other bodies have also published independent CIAs. In 2015, after a debate in the House of Commons, the Centre also engaged in a prolonged, but ultimately fruitless discussion with the Office of Disability Issues (ODI), within the Department of Work & Pensions (DWP) on this issue. Ultimately we came to the view that the ODI and the DWP had no serious intention of either developing their own CIA or of explaining how to improve the Centre's methodology or data. Instead its intention seemed to be to merely go through the appearance of having engaged, but in a way that could actually create no improvement in knowledge.

In 2018, after further pressure from Ian Jones, of the WOW Campaign, a letter was written by the current head of the DWP, Amber Rudd MP, to the current Prime Minister, Theresa May MP. This letter provides a summary of the DWP's reasons for not producing a CIA. Furthermore Debbie Abrahams MP and Kate Green MP have organised a debate on this issue in the House of Commons. Therefore, at the request of the WOW Campaign, the Centre has published its analysis of the Government's reasons for not producing a CIA.

In summary, the Centre found no good reason for the Government not to evaluate the combined impact of its own policies. The only plausible reason for the Government's failure is that the Government knows that any such analysis will show that its policies have caused considerable harm to disabled people and to other disadvantaged groups. 

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The publisher is the Centre for Welfare Reform.

Cumulative Impact Assessment (CIA) © Dr Simon Duffy 2018.

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