Framework for Action on Independent Living Consultation Response

Below is the text of my response to the Welsh Government consultation on the Framework for Action on Independent Living, from 20th December 2012.

The consultation documents can be found here.


My starting point is to endorse and commend Welsh Government’s adoption of the social model of disability. The stated aims of this Framework re-affirm this principled position, whilst setting out a way forward in applying these principles to make services more effective and accessible to people.

I feel the Framework goes a long way to recognising the assault on disabled people currently being exacted as part of the ‘welfare reforms’. The changes being imposed on disabled people have a much wider effect than the direct economic consequences. The implementation of the ‘welfare reforms’ has produced an impact on public attitudes, through their presentation and use of language, making many disabled people’s world feel more harsh and threatening. This compounds the vulnerability of some disabled people in the current crisis.

Nevertheless the Framework is correct in recognising the right to a decent income, sufficient to participate in society, as absolutely fundamental to making other rights ‘real.’ There is no value in having accessible train services, for example, if the people who would benefit from them cannot afford the fare.

The Framework rightly emphasises the importance of disabled people’s organisations, and the need to strengthen the capacity for collective action amongst disabled people. Such organisations are part of a long tradition of collective action in Wales and that capacity needs be preserved into the future.

I recognise the strong support which has been provided by disabled people’s organisations, and others, to the Welsh Government’s proposals to make direct payments more widely available and easier to access. There are, however, important implementation issues here which, I believe, need to receive proper attention with the Framework.

Direct payments have the potential to help to provide valuable individualised services that address very specific needs in a personalised way. To date, however, the evidence suggests that these advantages have been experienced primarily by those who have the greatest confidence and expertise in administering their direct payments, rather than those who have the greatest need. Even with the new arrangements which the Welsh Government envisages, the majority of social care users will continue to choose services provided through the local authority. The new arrangements needs to guard against any danger that individualised arrangements may erode the service choices of most users, by reducing the scope of local authorities to respond to them.

At the same time, renewed attention needs to be paid to the position of users and workers within Direct Payment provision. A race to the bottom, in terms for example of pay the pay and conditions of those employed as home care workers will not be in the short or long term interest of users either. Over time it will adversely affect recruitment and retention which are necessary to give people the continuity of care that they need.

Therefore I would urge Welsh Government to help reinvent the collective risk-sharing models in this field, in contemporary conditions. I would specifically propose that Welsh Government should make it a requirement that in each Local Authority there would be at least one cooperative-based direct payments provider. Such cooperatives would be membership based, and open to both users and workers, in order to pool risks and rewards on a collective basis. This option should be actively promoted, and individuals’ attention positively drawn to its existence. Ultimately, the decision as to whether to participate should be entirely the individual’s choice, but there must be a responsibility to ensure they are aware that the option is there.

I believe there are examples within Wales that could inform the creation of cooperative models. Some have been included in the consultation document, such as the support offered to disabled people with administering direct payments by Diverse Cymru and the Shaw Trust. These are not all necessarily ‘fully’ cooperative models but they are nonetheless consistent with the values of a cooperative model and have extremely valuable experience and expertise to be drawn upon. It would not be a substantial step for such examples to be converted to a full cooperative model suggested here.

Finally, I warmly welcome the Welsh Government’s inclusion of the principle of co-production, alongside co-operation, as part of the core values of social care. The shift from a deficit to an asset based model of care is essential for the future. Users and providers of services must be jointly engaged in decision-making: each has something different, but of equal value, to contribute in order to ensure best outcomes. The inclusion of co-production as a principle in the Framework is very welcome. Now the challenge will be to make that principle felt in the way that services are provided on the ground. The Scottish Government has undertaken considerable work in this area and has published a set of practical ways in which co-production can be translated into practical action.  There is real scope for policy transfer in this area, I believe.

I look forward to seeing the Framework develop, and should there be any further detail I can provide on any of the above points please do not hesitate to contact me.




Mark Drakeford AM
Cardiff West