I thank the Chairman and the members of the committee for this opportunity to discuss with them the way medical eligibility criteria are established in regard to illness and disability-related social protection schemes. I thank my colleagues in the Disability Federation of Ireland and the Carers Association for their comments.
Before I commence my presentation I would like to introduce myself. I am Dr. Singh, deputy chief medical officer. I am accompanied by Ms Catherine Kellaghan, principal officer, based in Longford, with responsibility for disability allowance, invalidity pensions and carer's allowance; and Mr. Tony Kieran, principal officer, based in Letterkenny, with responsibility for the domiciliary care allowance, DCA.
I will start by sharing with the committee some information on the main illness, disability and carers schemes provided by the Department of Social Protection. The Department provides a wide range of income supports to people with illness, disability or caring needs. The importance of these schemes is underlined by the fact that in 2014 more than €3.4 billion was spent on the various illness and caring related payments. This accounts for around 17% of the overall expenditure of some €20 billion on social protection in 2014. On average, some 330,000 people received weekly payments from these schemes, excluding the annual respite care grant, during 2014.
The number of beneficiaries on all schemes has been increasing steadily. For example, the total number in payment increased from some 230,000 in 2004 to some 330,000 in 2014. Medical opinions are provided to the Department's deciding officers to assist them in determining eligibility for the relevant scheme. These opinions are provided by the Department's medical assessors who are fully registered medical practitioners with at least three years experience. Several of the medical assessors currently working in the Department have post graduate qualifications and experience in relevant specialties. All undergo a structured and focused training programme on commencing their duties as medical assessors and are involved in a continuous professional development programme.
At the outset, it is important to point out that medical assessors do not contest or refute the diagnosis provided by the customers doctor; the objective of the medical assessment is to ascertain the impact of the disability on the customer. That is, to assess the ability for suitable work or the need for additional care due to the illness or injury and the expected duration of recovery. Medical opinions are based on all available medical evidence submitted with the application and, if available, any prior medical evidence held on file is also taken into consideration. The medical assessor uses his knowledge, skills, experience and evidence based guidelines and protocols to provide an informed and unbiased medical opinion.
In undertaking the assessment process the medical assessor considers the following: first, the customer's impairment, that is, the illness or accident, what symptoms they currently have, what investigations, treatments, medical or surgical, they have received and the prognosis of the condition; second, the customer's account as to how they consider themselves to be adversely affected by their condition, with special emphasis on how it affects their ability to cope with the activities of daily living, ADLs, and work-related activities; third, the provision of additional medical evidence is encouraged and all evidence provided is considered in the assessment process, for example, specialist reports, results of investigations, X-rays, CT and MRI scans, and blood tests, etc.; and, fourth, the medical assessor also considers any stated or known co-morbidity, in addition to the primary condition.
The medical assessor’s opinion is provided to the deciding officer, who then takes into consideration the medical opinion and all relevant criteria for eligibility to the particular scheme, including reviewing the medical evidence provided by the customer before making a decision on the application. The Department accepts that some customers may find the process of determining eligibility difficult, and that a perception may exist that some schemes are hard to qualify for. The following issues have been identified and are being worked on: familiarity or knowledge of the different schemes and the conditionality attaching to them; the level and type of information required at the initial application stage; the fact that it is not the diagnosis but rather the severity of restriction or disability and the expected duration of recovery that is taken into consideration by the medical assessment process; and issues relating to the communication content of decisions.
The Department continually updates information on its website on all schemes, ensuring that information on the purpose, conditionality and information required to be submitted with claims is available to potential customers. Information on the Department's schemes is also available through a wide range of providers, such as, the Department's Intreo offices, citizens information centres and non-governmental organisations. The Department continually stresses the importance of providing as much information as possible on the customer's medical condition with the initial application form. All correspondence issuing to customers stresses this point and encourages them to submit any additional information they may have. I avail of this opportunity to once again highlight to the committee that one of the main reasons for a claim being disallowed at the initial claim stage is that claimants and their doctors often do not provide full and comprehensive details of their condition or disability until they receive notification of a disallowance. The Department has a series of stakeholder forums with disability organisations and representative groups and avails every opportunity to emphasise the importance of providing full information at the initial claim stage.
The Department accepts that it is difficult to get across the concept that it is not the diagnosis but rather the severity of restriction or disability that is taken into consideration by the medical assessment process. To address this, the Department has undertaken a proactive engagement with medical stakeholders including meeting with general practitioners and their representatives. The chief medical officer and deputy chief medical officer liaise regularly with individual general practitioners who have issues or need clarification on specific scheme conditionality. This process is ongoing. Furthermore, these issues are also discussed in ongoing liaison meetings with customer representative groups, that is, the Carers Association, the DCA support groups, and the Disability Federatiion of Ireland.
The Department endeavours to provide as much information as possible on the reason for decisions. Specifically, in any case where an application is being refused additional information is now provided to the customer, which should assist them in deciding whether they should seek a review of the decision or appeal. This process is kept under continual review, with the intention of improving the service and making it as supportive as possible to the customer.
Before concluding, I wish to highlight a number of recent initiatives. The Department undertook a review of the DCA in 2012, all the recommendations of which have been implemented, a major service delivery modernisation programme was implemented in the past three years and a revised process to streamline access to invalidity pension from suitable claimants. These projects have resulted in a substantially improved service to customers, including improved communication. As always, the Department is committed to delivering the best possible service to its customers and continues to review and monitor its processes to ensure it provides a quality service to customers with illness, disability and caring needs.