The European Anti-Poverty Network (EAPN) Ireland
Europe 2020 Working Group
Comments on National Reform Programme 2015
15th April 2015
Contact: Paul Ginnell. EAPN Ireland, Equity House, 16 Upper Ormond Quay, Dublin 7, Email: [email protected] Tel: 01-8745737
The European Anti-Poverty Network (EAPN) Ireland Europe 2020 Working welcomes the opportunity
to comment on the draft NRP 2015. While we accept that the NRP is limited in the amount of detail
it can contain many of our comments draw attention to points raised in our submission in March
which we feel have not been adequately addressed in the draft NRP. However, we are not
attempting to repeat the content of the submission.
Specific comments on draft NRP
1. CSR 1
The macro-economic Recommendation dominates the CSRs received by Ireland in 2014. The NRP
needs to highlight the importance of a balanced social, economic and environmental approach to
addressing macro-economic targets. It needs also to outline if and how poverty, equality and gender
impact assessment is being used or will be used in the future to inform policy decisions. While
recognising the need for fiscal responsibility this section should also recognise the need for social
investment to ensure access to quality services and supports that this has both positive social and
economic outcomes. Some of these points are also relevant for the overall Macro-economic section.
2. CSR 2
The section on health has no reference to addressing health inequalities. This is a key element of the
Government’s health strategy and the NRP needs to indicate how this will be achieved. The focus
should not be only on cost-effectiveness but on access to quality health care for everyone. EAPN
Ireland through the Better Europe Alliance has also highlighted the importance of access to universal
health care for everyone as opposed to a universal health insurance model as a means of developing
a single tier health system in Ireland.
3. CSR 3
We welcome the move for Intreo to begin to engage with those who are long-term unemployed. The
NRP also needs to outline how it will engage with other groups distant from the labour market,
including those on the One Parent Family Payment and Disability Allowance who wish to receive
their supports. This section also needs to address the culture of the public employment service
which needs to be based on a positive person centred approach to supporting people.
The NRP in the section on CSR 3 and on the employment target does not outline how or if an active
inclusion approach is used to frame the engagement of the public employment service with those it
engages with. This must involve an integrated approach addressing issues of adequate income,
quality services and working to ensure an inclusive labour market. This must also cover the issue of
access to quality work and a decent income.
Failure to implement this balanced approach will result in actions to address unemployment and
low-work intensity leading to increases in poverty and social exclusion for many people.
Youth Guarantee: The implementation of the Youth Guarantee needs to be strengthened on a
number of areas. This includes:
 Young jobseekers must have access to a sufficient range of quality education, training and work
experience places which meet their needs.
 It must be open to all young people. The plan as currently devised excludes approximately
20,000 young people who are in receipt of either a one parent family and/or disability payment.
 An active inclusion approach must be applied to working with young people. This must include
access to the full rate of social welfare.
 Despite assurances that Government would engage with stakeholders in developing and
implementing the Youth Guarantee, there has been no consultation with organisations
representing young people and youth organisations. This needs to be addressed.
Youth Strategy –Youth employment: A youth strategy and the focus of youth work must engage
with young people in a more holistic manner related to all aspects of their lives related to their wellbeing and social inclusion. It must not be limited to or dominated by measures to address
unemployment and access to the labour market for young people. Youth work must also be
adequately resourced so that youth organisations to be able to carry out this work effectively. This
will result in longer term social and economic benefits.
4. CSR 4
As highlighted above we welcome commitments in Pathways to Work to expand the services of the
public employment services, including Intreo to those who are long-term unemployed and also to
begin to expand it to others of working age who are more distant from the labour market. Again to
highlight that this must include those on the One Parent Family Payment and Disability Allowance
who wish to receive these supports and that supports are provided in a positive culture and in the
context of an integrated active inclusion approach.
The ‘welfare reforms highlighted for lone-parents in the draft NRP, including to the income
disregard, are not consistent with an active inclusion approach and will undermine the goal of
supporting lone-parents to move into and stay in employment.
The report from the Advisory Group on Tax and Social Welfare on working age income supports and
the welfare to work transition, which was due for publication and mentioned in the 2014 NRP, has
not been published and is not referred to in this draft. While we welcome the Back to Work Family
Dividend (BWFD) as a positive measure further policy developments are needed to address gaps and
barriers to support this transition to work.
In relation to Childcare and ECCE, the issue of future investment is critical in bridging the current gap
highlighted in the CSR for Ireland and if Ireland is to move towards the development of a
comprehensive quality, affordable and accessible ECCE service. This is particularly crucial for low
income families, including one parent families. This will involve a high level of further investment in
services. See our initial submission and inputs from the Better Europe Alliance on the CSRs for
greater details.
Section 4: Progress Towards our Europe 2020 Targets
This section needs to recognise the interdependence between the different targets and the policy
measures to address them. Policies in one area can support or undermine progress in another. This
includes measures to address climate change and to support research and innovation which can help
to address poverty and social exclusion. In progressing their own commitments Departments need
to be reminded and supported to work as part of a whole of Government as opposed to a silo
approach to achieving the Europe 2020 targets and implementing the Country Specific
Recommendations.
The NRP also needs to set sub targets or at a minimum to report on the employment, education and
poverty outcomes for specific social groups with poorer outcomes or participation rates than the
general population. If this is not done then some groups will be left behind while progress might be
made towards the overall target.
Target 1- Employment
As with the earlier section dealing with CSR 3 this section does not incorporate an active inclusion
approach to its policies in supporting access to the labour market for those who are more distant.
The NRP also needs to report on progress in increasing the employment levels of groups most
distant from the labour market. While reporting on the gender gap in employment rates the NRP
also needs to outline the policy measures in place to address this gap. Failure to implement policies
to address this gap will result in a return to gender segmentation in the labour market. While
addressing caring responsibilities is part of this solution other measures are also needed e.g.
addressing the gender pay gap.
There is a need for the NRP to address the demand side of employment in greater detail. While the
section on CSR 4 outlines some positive measures in relation to engaging employers, more specific
measures are needed to address the particular barriers faced by groups more distant from the
labour market. These demand side barriers also existed prior to the crisis when there was deemed to
be ‘full employment’ while in reality participation rates for certain groups was low. Some of the
demand side issues which need to be addressed in a strategic manner include tackling discrimination
in access to employment and in workplaces and creating greater flexibility in the workplace, while
maintaining quality employment standards. There is also a separate but linked issue of ensuring the
availability of employment opportunities across the country. This is a particular issue for those in low
income jobs due to the costs incurred in travelling to work or in extra care costs for dependents.
The draft NRP currently does not cover the issue of quality work and decent pay. This has been
highlighted as a key issue and of not addressed will result in undermining commitments to reduce
poverty. Our submission contained the following section on decent work:
The establishment of the Low Pay Commission is welcome and we look forward to speedy action to
address the adequacy of the national Minimum Wage and to tackle the problem of precarious work.
The Living Wage Technical Group has highlighted that an hourly rate of pay of €11.45 for an
individual working full-time is necessary to provide them with a basic, adequate standard of living1.
This highlights the inadequacy of the National Minimum Wage of €8.65 to provide workers with an
adequate income. Currently Ireland is rated as having the second highest proportion of low-paid
workers in the OECD.
While an adequate hourly rate is a critical element of decent pay for workers it is only one element
of ensuring that workers and their families have an adequate weekly income to provide them with a
decent standard of living. The issue of precarious work is a particular problem which needs to be
tackled if people are to have a quality working life and a decent standard of living. A 2012 report on
decent work by the Mandate Trade Union graphically illustrates the issues around decent pay2. The
number of hours worked and how income from work interacts with social welfare supports is critical
to ensuring a decent standard of living. There are also particular issue for low-paid workers who
have dependents for whom they will have to pay for care services.
While access to a quality job which provides workers with a wage that enables them and their
families to have an adequate standard of living, is the ideal, many low paid workers rely on access to
social welfare supports to supplement their income. However, many elements of the social welfare
system are inflexible and many very low paid workers cannot qualify for supports.
The following are some of the specific issues which would contribute to improving the situation for
workers.
 Under the current system, part time workers can only qualify for jobseekers’ payments
(Jobseekers Benefit and Jobseekers Allowance) if their hours are worked within three days
or less in a week. Many low paid part-time workers, even if working only a small number of
hours, have these hours spread over more than three days thus making them ineligible for
social welfare support. The criteria for access to jobseekers’ payments should therefore be
changed from one based on days to one based on hours.
 The Social Welfare Act 2011 reduced the length of the social welfare week from 6 to 5 days
for those in receipt of Jobseekers Benefit. This change was presented as a measure to
encourage people to take up work by making it a more attractive alternative. However, in
the experience of EAPN Ireland members it is having the opposite impact and acting as a
barrier to employment due to the reduction in the ability of part time workers to earn an
adequate income by combining income work and social welfare supports. The social welfare
week for Jobseekers’ Benefit should be changed back to a six day week. This change has
been further compounded by the change in the social welfare week from a 6 day one to a 7
day one when unemployed people take up work.
 The Family Income Supplement (FIS) plays an important role in supplementing the income of
low paid workers protecting them from the worst impact of low income from work.
However, despite information campaigns on FIS, many people who are eligible do not access
it. The application process for FIS also involves the employer, which can act as a barrier to
application even for those who are aware of it. The Family Income Supplement needs to be
reformed so that those who qualify for it automatically receive it.
Following the coming into force of the the Industrial Relations (Amendment) Act 2012 which reforms
the Joint Labour Committees and Registered Employment Agreements (REAs) wage-setting
mechanisms, the Labour Court is still in the process of putting in place the infrastructure for the new
JLCs. This process needs to be sped up and is essential that the JLCs are set at a level which provides
workers with a fair wage for their work.
1
www.livingwage.ie
Mandate Trade Union (2012), Decent Work? The Impact of the Recession on Low Paid Workers,
http://issuu.com/mandate/docs/mandate_decent_work_report_2012
2
The NRP needs look at the above issues and outline in a comprehensive manner how the issue of inwork poverty and decent work will be addressed as an integrated part of its jobs strategy. The work
of the Low Pay Commission can contribute towards this.
Target 4 - Education
The EAPN Europe 2020 Working Group supports measures that are outlined to address disadvantage
in education and to support equal access to third level for people from all groups and communities.
The draft NRP outlines a range of measure in place to address this.
However, the draft does not address the two issues raised in our submission to the NRP which relate
to equitable education outcomes for specific groups of marginalised young people and literacy and
numeracy supports for those with lower qualifications. Our proposals were as follows:
1.
The education target could be achieved without any improvement in the educational
outcomes for children from some of the most marginalised groups. There therefore needs to be subtargets under the education target which can highlight the different participation and outcome
levels for specific groups of young people. This can help to ensure more equitable educational
outcomes for all children and social groups across the whole system. This includes Traveller children,
children with disabilities or special learning needs and children living in disadvantaged areas.
Including sub-targets would result in a greater focus of policy development and implementation for
these groups of children either in terms of mainstream policy or the development of specific
measures. It might also prevent future cuts or changes to supports for these groups without first
thoroughly investigating the implications of these cuts on participation and outcomes.
2.
The education target needs to include an adult literacy target. This is a major gap under the
current target and would strengthen and prioritise policy responses to adult literacy.
All publically funded education and training programmes (to level 6) should adopt an integrated
approach and embed literacy and numeracy development within courses. In 2007 the National Skills
Strategy (NSS) suggested that by the year 2020 there should be 45% with qualifications at levels 4
and 5 and 7% with qualifications at NFQ levels 1 to 3. This equates to up-skilling nearly 300,000
workers with basic education needs. The latest report on the implementation of the National Skills
Strategy shows that the slowest progress made so far has been with up-skilling those at FETAC Levels
of 1 - 3 up to Levels 4 and 5. This group was identified as the most significant challenge to up-skill for
the period to 2020. A key factor in delivering on the targets is ensuring the acquisition of literacy and
numeracy skills.
The National Reform Programme therefore needs to report on the goals set out in the National Skills
Strategy including addressing specific challenges related to literacy and numeracy. This must include
the provision of more intensive and flexible opportunities for adults to develop their literacy and
numeracy skills, in particular at Levels 3 and 4 for people who are unemployed. This should include a
greater use of blended learning and distance learning approaches.
Target 5 – Poverty and social exclusion
Considering the high and increasing levels of poverty and social exclusion and the reality of this
experience for people and communities this section is weak on the policy measures to address it.
The draft NRP highlights that the active inclusion strategy which presents the frame for meeting the
national social target for poverty reduction is based on the ‘developmental welfare state’, as
outlined in the National Action Plan for Social Inclusion (NAPinclusion). However, the actual policy
measures outlined in the draft do not present what would constitute an integrated active inclusion
strategy or approach. While recognising the limits of an NRP, this section needs to be more
comprehensive in how the three elements of active inclusion are to be achieved across the lifecycle
and for disadvantaged groups.
For example:
 In relation to adequate minimum income there is no mention of the gap between social welfare
rates and what it takes for different families to have a minimum essential standard of living or
even to achieve the 60% at-risk of poverty income threshold. This section needs to highlight
what the impact of changes to support for lone-parents and one parent families will have on
their incomes as group with already extremely high poverty levels.
 Measures to create an inclusive labour market are dealt with above and in more detail in our
submission. This must include addressing issues of quality work and decent pay.
 The section on access to quality services needs to be wider and attempt to provide an update
on progress and challenges in providing the range of quality services that are needed and
measures to improve access to these.
An active inclusion approach is also only part of what is needed to an integrated strategy to address
poverty and social exclusion as called for by EAPN Ireland. It must also address other areas such as
the redistribution of wealth, cross cutting issues including discrimination and the effective
participation of people in decisions that impact on them.
This wider, integrated approach must also apply to updating and extending the current National
Action Plan for Social Inclusion 2017-2016. An updated strategy, even though for a short period,
must reflect an integrated approach which address the multi-dimensionality of poverty and social
exclusion and not be solely a series of disconnected goals and measures. Given the depth of poverty
and social exclusion it must also be ambitious.
The draft NRP section on Institutional Issues and Stakeholder Involvement highlights the input from
participants in the Social Inclusion Forum on an updated and extended National Action Plan for
Social Inclusion. It will be important that this input is reflected in the updated strategy and that it is
only one stage in a wider consultation. As highlighted in the preparation meetings for the Social
Inclusion Forum and in the Forum itself participants need to see how their engagement impacts on
policy, with frustration expressed at the apparent lack of impact over the past number of years. This
is also reflective of engagement with the wider Europe 2020 and Semester process.
As soon as feasible there is urgent need to begin to develop and fully integrated five year successor
to the extended National Action Plan for Social Inclusion which needs to be developed through an
effective consultation process.