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move off benefits entirely, are they sanctioned again, do they move
                   into work?

          2.58  We are pleased to hear that the DWP is working on ways to aggregate data on
               claimant vulnerabilities and support needs, 133  and has assured the SSAC that
               action on its 2019 recommendation to prioritise data collection and analysis
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               on the application of discretion (and easements) is being undertaken.
          Claimant commitments and easements


          2.59  As  sanctions  are  imposed  for  failing  to  comply  with  the  claimant
               commitment, without good reason, the setting of the claimant commitment is
               an integral part of the sanctions regime. The claimant commitment is meant to
               be tailored to individuals’ circumstances. Under the Equality Act 2010, work
               coaches are also under an obligation to make reasonable adjustments for those
                              135
               with disabilities.  However, the DWP’s UC Full Service Survey found that
               only  54  per  cent of  UC  claimants  believed that  their  claimant commitment
               took their personal circumstances into account and only 63 per cent felt it was
               achievable.  This is echoed by the SSAC which found that some coaches are
                         136
               not applying discretion fairly and systematically, leading to commitments that
               are not truly tailored to a claimant’s needs and circumstances. These findings
               are underlined by the Work and Pensions Select Committee which has found
               that claimant commitments result in unachievable commitments, in particular
               for  vulnerable  groups  with  complex  circumstances,  such  as  those  who  are
               homeless,  single  parents  and  suffering  from  health  conditions. 137   This  also
               indicates  that  work  coaches  are  not  always  complying  with  their  positive
               duties under the Equality Act to make reasonable adjustments for those with


          133  P. Schofield, ‘Work and Pensions Committee Oral evidence: DWP's response to the coronavirus
          outbreak, HC 178’ (February 2021), Q430.
          134  SSAC, A review of the Covid-19 temporary measures (see n.12 above) p.15.
          135  The Equality Act 2010 does not apply in Northern Ireland, however, the duty to make reasonable
          adjustments exists under the Disability Discrimination Act 1995.
          136  Government Social Research and the DWP, Universal Credit Full Service Survey (see n. 8 above)
          p.40.
          137  Work and Pensions Committee, Benefits Sanctions (see n. 11 above) pp. 43-44.


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