Association of Sign Language Interpreters (ASLI) response to:
Pathways to Work: Reforming Benefits and Support to Get Britain Working Green Paper

Written by Darren Townsend-Handscomb with input from ASLI membership.

Downloadable version: Pathways to Work Green Paper Response

The Association of Sign Language Interpreters (ASLI) is a professional membership association and support network for British Sign Language (BSL) Interpreters and Translators in the UK.

We exist to represent and promote the BSL Interpreting and Translation profession. BSL/English interpreters’ careers are spent working closely with deaf people, their employers, colleagues and customers across all sectors and all sizes of business, sometimes for many years. We see at first hand the successes and frustrations of deaf people in the workplace, including those with Access to Work and their employers.

This feedback, and these recommendations, have been gathered from consultation from our membership and experienced advisors and are drawn from everyday observation of lived experience.

Throughout our answers we talk about the need for information to be available in BSL. To save repeating this suggestion in full under every question this is what we mean when we make this recommendation. We suggest following the Government Communications Service (GCS) Guide to BSL translating and interpreting for public-facing communications’ and working with specialist in communicating with deaf audiences. The alternative approach, which is often expensive and not in fact accessible, is to translate everything written into BSL. We raise this because this was the approach taken with this consultation and deaf people have fed back that a single almost five hour translation is not useable.

Whilst our focus is on deaf people who use BSL, almost all of our feedback and recommendations would apply equally to deaf English users, deafblind people, people with other disabilities and those with long term health conditions.

1. What further steps could the Department for Work and Pensions take to make sure the benefit system supports people to try work without the worry that it may affect their benefit entitlement?
ASLI welcomes the proposal to introduce the “right to try”. ASLI members report that they regularly work with Deaf people who want to work, but who are concerned that even trying work could put their benefits at risk.

The “right to try” should be a guaranteed trial period for at least six months, giving sufficient time for people to test out work without any changes to their benefit entitlement. This gives time to settle in, find out if the job is manageable and see whether reasonable adjustments are sufficiently met. If the trial does not succeed there should be prompt and frictionless reinstatement of benefits.

However, with current Access to Work delays six months may not be long enough for people to get the work support they need in place. For the “right to try” to work for deaf people Access to Work would need to be able to be able to assess and approve a support package in sufficient time before the start date for the new job to allow support workers to be booked and be able to quickly amend the support package if needed.

But it won’t matter how good the “right to try” is if deaf BSL users don’t understand it because the information is only in English, and so it is essential that all resources are available in BSL.

For support conversations to be genuinely helpful in assisting deaf BSL users into employment they must be offered on a purely voluntary basis. To establish trust and prevent these discussions from being perceived as assessments, they should only occur after determining a claimant's eligibility for the health-related benefit component.

The design of these support conversations requires input from deafness specialists, given that BSL users represent a low-prevalence but high-needs group. Each conversation must be carefully personalised, taking into account the individual's unique skills, challenges and personal situation.

When implemented, these support discussions should be conducted by professionals with appropriate knowledge of deafness and BSL, who understand the complex needs of the deaf community. Considering the current lack of trust many claimants have in the DWP, engagement rates would likely improve if these conversations were facilitated by specialist external organisations with expertise in supporting deaf people into work, rather than being DWP-led.

2. What support do you think we could provide for those who will lose their Personal Independence Payment entitlement as a result of a new additional requirement to score at least 4 points on one daily living activity?
There must be clear communication in accessible formats including in BSL, so people understand what’s happening and what their options are. Sudden loss of support can be overwhelming and if people aren’t even sure why they’re losing their entitlement, it can lead to serious distress.

There should also be a transitional support package. If someone is losing PIP they should be offered a reduction in support over time and not an abrupt stop. That would at least give people time to adjust, seek alternative help or appeal .
Anyone who loses entitlement should be given direct access to support from an advocate or other professional who can help them understand appeals and access other benefits they may now need.

3. How could we improve the experience of the health and care system for people who are claiming Personal Independence Payment who would lose entitlement?
Whilst the suggestions below would benefit all deaf people and not just those who lose entitlement, by addressing these barriers to healthcare for deaf people you remove some of the factors that lead to poorer health for deaf people, which then add an additional barrier to paid work for many deaf BSL users.

These healthcare access barriers for deaf people, are documented in SignHealth’s Sick Of It report. Enacting Section 95 of the 2022 Health and Care Act would strengthen the NHS Accessible Information Standard’s legal standing and ensure compliance through robust measures, including for monitoring and enforcement. REF.
https://signhealth.org.uk/resources/report-sick-of-it/ 

As well as this, we ask that the UK Government undertake the recommendations contained in the “Report to NHS England on the outcome of a Rapid Review of commissioning arrangements for British Sign Language interpreting services” REF
Report to NHS England on the outcome of a Rapid Review of commissioning arrangements for British Sign Language interpreting services, NECS Senior Consultancy Team, July 2021.
https://ukcod.org/wp-content/uploads/Campaigns/NECS-Rapid-Review-full-report.pdf

We also recommend the UK Government provide a 24/7 BSL Health Access remote interpreting service, free at point of use, to enable deaf people to access any health care. This would address gaps in provision, and services not covered by BSL 999 and BSL 111. The
pilot of this service undertaken by SignHealth during covid demonstrated the need for and impact of this. REF.
https://signhealth.org.uk/press-release/no-money-bsl-health-access-is-closing/

Further, we recommend that there should be mandatory deaf awareness and BSL training for all NHS and social care staff, along the lines of the current mandatory training in autism.

Tendering for BSL interpreting within NHS Trusts tends to favour large spoken language agencies, which often are unable to deliver, either at all, or of sufficient quality. Encouraging CCGs and Trust to contract with smaller specialist agencies will improve this. As will making it possible for deaf people to book, and have confirmed, BSL interpreters for appointment, e.g. through a digital platform or app.
There are currently insufficient BSL interpreters to meet demand, including within health settings and so government should undertake workforce planning to continue to increase the number of BSL interpreters available.

4. How could we introduce a new Unemployment Insurance, how long should it last for and what support should be provided during this time to support people to adjust to changes in their life and get back into work?
We believe the new Unemployment Insurance should not impose time restrictions or enforce work-related conditionality for claimants with disabilities or chronic health conditions.

Time-limiting the Unemployment Insurance would be particularly unfair when we know that deaf people face additional barriers to work, with only 37% of people who report BSL as their main language working, in comparison to 77% of people who are not disabled under the Equality Act.

If government proceeds with time limiting the Unemployment Insurance, we believe that for people who qualify as disabled under the Equality Act it should last significantly longer for deaf BSL users to reflect the impact of those barriers to entry.

We note that if time restricted it is imperative that the UK Government ensure that all staff involved in supporting back to work have deaf awareness training, that specialist providers able to deliver in BSL are used wherever possible, interpreters are always booked and not a barrier to support, resources are all available in BSL and Easy Read, and ATW is improved to remove delays.

Members were also concerned that there should be prompt access to mental health services in BSL whilst unemployed to provide the foundation for deaf BSL users to enter or continue in work.

5. What practical steps could we take to improve our current approach to safeguarding people who use our services?
Ensure that all communications with deaf BSL users, where the deaf person says that this is their preference, are provided in BSL and English, including letters, emails and other resources. Not doing so increases the risk of people missing or misunderstanding crucial information.

Provide clear signposting to where deaf BSL users can report safeguarding concerns and ensure that this can be done in BSL.
Ensure that only registered BSL interpreters are booked for appointments.

We support the establishment of coaching academies for Jobcentre staff and propose that they incorporate mandatory training on effectively engaging with deaf and deafblind clients, including protocols for securing interpreter services.

We recommend that DWP Build and deploy a proxy log-in to the ATW portal so that Support Workers can support Access to Work customers with submitting claims and administering their Access to Work. This log-in should ensure traceability of who used the proxy log-in.

6. How should the support conversation be designed and delivered so that it is welcomed by individuals and is effective?
We cautiously welcome the principle of support conversations if they are properly designed and implemented. However, significant work is needed to ensure they effectively address the multiple barriers deaf BSL users face in accessing employment.

For these conversations to be successful, they must:

•Remain entirely voluntary to encourage genuine engagement
•Only occur after a claimant's eligibility for the health element has been confirmed, to avoid any perception of being an assessment
•Be developed in consultation with deaf specialists who understand the specific needs of BSL users

Given the DWP's current lack of trust among many deaf claimants, we believe these conversations would be more effective if delivered by specialist organisations with proven expertise in supporting deaf jobseekers, rather than by DWP staff.

Even if initial attendance at support conversations is required, participants must retain the unconditional right to decline any support options offered. Given the specialist needs of deaf BSL users, many proposed options, particularly if delivered by non-specialist providers, may be inappropriate or ineffective.

7. How should we design and deliver conversations to people who currently receive no or little contact, so that they are most effective?
To maximize the effectiveness of support conversations for deaf BSL users who currently have minimal or no contact with the DWP we propose that support conversations should be offered as an opt-in service rather than being mandatory, with claimants receiving clear information in plain English and BSL about what the discussion involves. Explicit reassurance must be provided that participation will not affect any benefit entitlements. Participants should have choice regarding the communication channel, such as in-person or video call options, and the venue for these conversations. For individuals with limited prior contact with the DWP, the process needs to be explained in an accessible and thorough manner. Where these conversations are delivered by external organisations, the initial contact should be handled by the provider rather than the DWP to maintain trust and clarity.

Many isolated Deaf individuals rely solely on Deaf centres or specialist services for connection, so information about support conversations must be shared directly with these organisations in BSL and in culturally appropriate formats. The conversations themselves need to be fully accessible, with qualified BSL interpreters provided whenever required. To ensure widespread awareness, a social media campaign delivered in BSL should explain this new support option and demonstrate how to request it. This campaign would help reach the Deaf community directly in their preferred language and through appropriate channels.
For additional recommendations, see our response to Question 6.

8. How we should determine who is subject to a requirement only to participate in conversations, or work preparation activity rather than the stronger requirements placed on people in the Intensive Work Search regime.
We disagree with proposals to extend work conditionality and benefit sanctions to deaf BSL user claimants who are currently exempt. This position is supported by the UK Government’s own research in The Impact of Benefit Sanctions on Employment Outcomes, which demonstrates that sanctions fail to improve employment prospects.

Evidence shows that voluntary, personalised employment support, coupled with firm guarantees about benefit security, offers the most effective pathway to rebuilding trust in DWP services. For this to work decisions must be based on individual circumstances and needs, rather than applying rigid, universal requirements.

For many Deaf BSL users, additional systemic barriers compound these challenges, including limited or no fluency in written English. Given this deaf BSL users in the Intensive Work Search regime should have appropriate support organised from before the start the regime, support should be provided by specialist organisations with proven expertise in supporting deaf jobseekers, and no sanction should be applied if the support was not adequate.

Frontline staff require comprehensive training to properly identify these barriers and exercise appropriate discretion in individual cases.

9. Should we require most people to participate in a support conversation as a condition of receipt of their full benefit award or of the health element in Universal Credit?
We do not support making participation in a support conversation a requirement for most people to receive their full benefit entitlement or the health element of Universal Credit.

As we stated in our response to question 8, we are against expanding work conditionality and sanctions for those currently exempt. The UK Government’s own research, The Impact of Benefit Sanctions on Employment Outcomes, has shown that sanctions do not help individuals secure employment.

We strongly believe that voluntary, tailored employment support, combined with clear assurances that benefit entitlement will not be withdrawn, is the most effective way to build trust in DWP services and assist people, when appropriate, in finding suitable and rewarding work.

As in our answer to question 6, support conversations should be facilitated by staff who have proper training and understanding of deaf BSL users, preferably by specialist organisations with proven experience in supporting deaf jobseekers and who are sensitive to the complex needs and circumstances of deaf people who use BSL.

10. How should we determine which individuals or groups of individuals should be exempt from requirements?
As we stated in our response to question 8, we are against expanding work conditionality and sanctions for those currently exempt. The UK Government’s own research, The Impact of Benefit Sanctions on Employment Outcomes, has shown that sanctions do not help individuals secure employment.

We strongly believe that voluntary, tailored employment support, combined with clear assurances that benefit entitlement will not be withdrawn, is the most effective way to build trust in DWP services and assist people, when appropriate, in finding suitable and rewarding work.

If deaf people are not exempted from requirements, then there should be individual assessment from specialist providers who have an in depth understanding of deaf people and the individual and systemic barriers they face.

Should deaf people not be exempted from these requirements then the decision should be made on an individual basis, conducted by specialist providers who have an in depth understanding of deaf people and the individual and systemic barriers they face, considering all of their disability, health, access needs, and specific circumstances.

11. Should we delay access to the health element of Universal Credit within the reformed system until someone is aged 22?
No, as this would remove financial support that some young deaf BSL users rely on, including some who may be receiving Universal Credit whilst beginning work.

12. Do you think 18 is the right age for young people to start claiming the adult disability benefit, Personal Independence Payment? If not, what age do you think it should be?
Young people should have the flexibility to choose when between the ages of 16-19 they transition to adult disability benefits, mirroring Scotland's approach. This would allow them to time the change to reflect the transition from education to employment, which occurs at different ages for different young adults.

13. How can we support and ensure employers, including Small and Medium Sized Enterprises, to know what workplace adjustments they can make to help employees with a disability or health condition?
Deaf people consistently report (RNID 2013, 2018, 2019) that employer attitudes are the main barrier to employment. This is important because whilst addressing any knowledge gap is an important part of the UK Government’s work to change employer behaviour and increase the numbers of deaf and disabled people in work, it is insufficient, and a whole system approach is required.

RNID. (2013). Hidden Disadvantage: The impact of hearing loss on employment in the UK.
RNID. (2018). Working for Change: Survey results. Action on Hearing Loss.
RNID. (2023). The impact of hearing loss at work.

The proposed cross-Government development of a digital support offer for employers is a useful strand in addressing the employer knowledge gap.

Such a resource should contain:
•Guidance and resources to help employers recruit, retain, develop, and support deaf employees
•Insights for employers on systemic and indirect barriers deaf people face in the workforce, with practical steps to remove them (e.g., alternatives to phone interviews)
•Real-world examples and case studies, including effective reasonable adjustments
•Bite sized resources easily applied to the workplace, e.g. top tips, checklists ‘have you considered’, etc
•Signposting to additional support programmes and funding opportunities
•Details on Access to Work and how employers can utilise it
•Management guidance / tips on effectively working with and supporting deaf staff
•Deaf awareness and interpreter training for workplaces, and other webinars as useful

The hub should be co-produced with disabled people, support organisations and key stakeholders including employers of various sizes, and itself should demonstrate the inclusion and accessibility you are asking employers for. I.e. do not assume in designing this that all employers are non-disabled.

The Access to Work BSL Adjustments Planner is one way that deaf BSL users could be facilitated to have more structured conversations with potential and existing employers about their communication needs and any other requirements for reasonable adjustments. However, awareness of this within the deaf community is very low. We suggest developing resources for deaf schools and colleges, and mainstream schools and colleges with deaf children and young people, so that deaf BSL users can begin thinking about and recording their communication needs as early as possible. It should also be part of an ATW induction process for all deaf BSL users new to Access to Work.

Whilst the focus has been on numbers, we believe that regular research on deaf people’s experience of applying for, working and developing at work will be required both to understand the successes and failures of any interventions, but also to inform the development of targeted resources for employers.

If and once the delays and resource limitations of ATW have been addressed there should be a rolling communications campaign to inform employers and deaf BSL users about ATW and the resources available.

To support employers to know what workplace adjustments they can make to help deaf employees we recommend that ATW establish an ‘Independent Adjustments Advisory Service’ supporting employers and ATW customers. This would support the recruitment and development of staff with appropriate skills and, as the goal of the conversation is no longer for the adviser to reduce Access to Work costs, facilitate a more honest and useful conversation. Employers report that these conversations are currently often not dealt with well.
We recommend the UK Government implement measures that encourage employers to hire disabled individuals and adopt necessary workplace adjustments. Specifically, we endorse the Good Growth Foundation’s (GGF) proposal for a National Insurance Contributions (NICs) holiday for employers who recruit from health or disability benefit claimant pools. According to GGF’s analysis, this tax incentive could generate annual savings of approximately £1.1 billion through reduced benefit expenditure and increased employment REF. We maintain that this approach represents a more effective and sustainable method for achieving cost efficiencies while meaningfully supporting disabled people’s entry into employment.

Good growth Foundation, 2025. National Insurance Holiday for Firms Hiring Those on Benefits Can Save £1.1 billion Per Year. Available from https://www.goodgrowthfoundation.co.uk/press/national-insurance-holiday-for-firms-hiring-those-on-benefits-can-save-11-billion-per-year

14. What should DWP directly fund for both employers and individuals to maximise the impact of a future Access to Work and reach as many people as possible?
We welcome the UK Government’s commitment to helping more deaf people enter employment, which will likely increase demand for Access to Work. To ensure deaf BSL users can successfully enter, remain, and progress in work, the scheme must be properly funded to meet this demand and provide timely support.

However, meeting this demand must not come at the expense of reducing existing support, such as lowering the funding cap, or by requiring employers to contribute more financially. Deaf BSL users and interpreters consistently report that ATW is the most impactful government intervention in enabling them to secure, retain, and advance in employment. It gives deaf jobseekers confidence to apply for roles, knowing they can assure employers, “If you hire me, I can arrange interpreting support. ”The same applies for deaf and deafblind people who work with deafblind interpreters, communicator guides.

While we oppose such changes, if they are to be introduced, they must only follow:

•Consultation and co-design with employers and ATW users,
•Differentiated expectations for reasonable adjustments, accounting for the size and nature of employers, including micro-enterprises, SMEs, large corporations, and self-employed individuals or company directors,
•A pilot scheme with evaluation before full implementation,
•An enforcement mechanism (with adequate resources) to ensure compliance with reasonable adjustments, without placing enforcement responsibility on disabled employees.

Crucially, high-cost support that would be unreasonable for employers to cover must continue to be funded by ATW to ensure equal opportunities for deaf workers. Increasing employer costs is likely to unintentionally discourage businesses employers from hiring deaf BSL users.

Before any changes, the UK Government must consult widely on ATW’s future role and design, ensuring reforms are co-developed with disabled people, charities, DDPOs and different sizes of employers.

The Department for Work and Pensions must ensure Access to Work is adequately resourced to process applications and renewals, and deliver support within four weeks, while also eliminating existing backlogs that currently jeopardise the government’s employment objectives.

To enhance efficiency, we recommend enabling ATW users to retain their existing support when transitioning between jobs, provided it remains suitable for their new role. This should be accompanied by a fast-track review process to assess the relevance of adjustments to the new position, reducing administrative burdens for both the DWP and users while ensuring continuity of support. This may be supported by the ATW BSL

Adjustments Planner if ATW sets up a process where what is recorded in this Planner is also recorded on the ATW system.
Additionally, a fast-track application route should be established for individuals who can clearly demonstrate their support needs, for example, through prior workplace adjustments or educational support arrangements. Where applicants provide existing evidence or assessments, the DWP should prioritise these cases to expedite approvals.

These measures would not only improve service delivery but should also optimise costs, ensuring timely support for disabled workers without compromising quality.

Access to Work must continue to provide the full spectrum of support options, including in-person, remote, and on-demand interpreting services. Currently, assistive technology and artificial intelligence solutions remain incapable of adequately meeting the communication needs of deaf BSL users in workplace settings. Before introducing any AI-based services, the UK Government must ensure these are rigorously tested with deaf BSL users themselves, rather than relying solely on claims from product developers who may prematurely declare their solutions ready for use. Some English transcription products are useful to some deaf people These could be evaluated for accuracy and bulk purchased to reduce the cost of provision.

Future potential seen in the AI sector will not be deployable in the near future despite industry claims and apparent appetite from funders. It is imperative that we do not slow investment in personnel whilst chasing a dream of a world where AI will replace people; communication support provided via ATW is at its centre a human interactive support provision and AI will have limited ability to replace this.

We recommend as well as a resource for employers, ATW builds a resource for disabled employees, e.g. offering low or no cost access to ATech software and updates. These low cost resources could be provided as a self-serve option to ATW customers who need them, removing the cost of assessment and staff time.

15. What do you think the future role and design of Access to Work should be?
We believe the future role of ATW should be to provide deaf and disabled people with the support they need to start, stay, and progress in work, covering costs beyond what is reasonable for employers to provide.

The Green Paper says that the current systems and processes ATW uses are complex, contributing to the backlog. ATW’s current IT systems are old and unable to take advantage of modern IT and AI improvements. For this reason, the ATW portal, whilst demonstrating the potential for improvement, has not delivered the expected efficiencies, as it cannot be connected to the current ATW IT infrastructure.
This ageing IT infrastructure is a barrier to efficient delivery and means that DWP cannot know what changes are necessary in order to achieve efficiencies, improvements, and meet the government’s broader goals.

We believe as a first step, and before any decisions are taken to change Access to Work, the UK Government should invest in Access to Work’s IT, digital, and data infrastructure.Through better collection of data this would put ATW in a better position to understand what operational changes are necessary and will also improve efficiency, cost effectiveness, and so support reaching more people without reducing support for those who most need it. For example, this could include Automating administrative tasks (not decisions), improve adviser tools and resources to support decision making, and expand self-service options (e.g., customer portal, live chat, FAQs).

This would build on the success of the online claims and renewal processes, as well as unlocking the full potential of the customer portal.
Separately, or as part of a digital modernisation program, Access to Work should also review policy, procedures, processes, customer facing materials, etc. to improve efficiencies and reduce friction.

For example:
•Clarifying award letters to prevent customer misunderstandings.
•Simplifying renewals for stable cases (e.g., same role, no underspending/overspending).
•Allowing flexibility (e.g., adjusting the mix of in-person vs. remote interpreting).

Our members report that increasing numbers of interpreters, including themselves and their colleagues, are reducing or declining Access to Work assignments due to persistent payment delays and concerns that awards may not be fully backdated when renewals aren't processed before existing awards expire. This issue requires urgent attention in reviewing resourcing and processes, as the consequence for ATW customers is a further reduction in an already limited pool of available interpreters.

We believe that the current Access to Work BSL Adjustments Planner offers an opportunity to improve the time-consuming and often repetitive application process when changing jobs, by enabling customers to ‘carry over’ support when they change jobs if the support is still suitable for the work role, with a light-touch review for suitability. This should be part of ATW’s onboarding process for new customers.
The current Access to Work delays if not successfully addressed will likely undermine the UK Government’s goal of increasing the number of disabled people getting and staying in work. Interpreters already report seeing deaf people miss out on job offers or struggle to cope in new roles simply because they’re waiting for funding approval for an interpreter.

Alongside crucial investments in IT modernisation and process improvements, the Department for Work and Pensions must ensure Access to Work receives sufficient funding to guarantee support is established within four weeks of application, renewals, Change of
Circumstance requests and claims are processed efficiently. Persistent backlogs would significantly compromise the government's goal of increasing employment opportunities for disabled people. ATW should also publish clear processing timelines to restore confidence.
As the UK Government pursues its ambition to get more disabled people into work, we expect demand for Access to Work to grow significantly. It is absolutely crucial that the scheme receives adequate resources to meet this rising demand and continue providing timely support, enabling deaf people to successfully enter, remain in, and progress through employment. While we strongly support increasing participation, the necessary funding must match this expansion - otherwise, stretched resources will negatively impact individual users' support.

The Green Paper's suggestion of shifting more support costs onto employers raises significant concerns. There is currently limited evidence that employers are prepared to cover substantial ongoing workplace access costs, even when financially capable. Access to Work must therefore maintain its vital role in supporting those with highest needs, particularly deaf BSL users and deafblind individuals. This core principle must not be compromised by any expansion of the scheme.

If Access to Work is to shift more of the cost of support on employers, the government must ensure this transition occurs only after thorough co-development with employers and ATW users, alongside a piloted and evaluated trial phase. Any such changes must also be accompanied by enforceable compliance mechanisms, with dedicated resources for monitoring and intervention. Critically, the responsibility for enforcing reasonable adjustments must never fall to deaf or disabled individuals themselves, as this would place an unjust burden on those the scheme is designed to support.

While the Green Paper suggests clarifying this expectation for employers, disabled individuals, and ATW itself, the scheme currently lacks concrete guidelines or illustrative case studies to demonstrate how this principle applies in practice. Decisions are made without formally assessing what constitutes a reasonable adjustment in each case.

For this principle to be properly embedded in ATW’s decision-making, the scheme must develop clear exemplar materials. These should show how the threshold of ‘reasonableness’ varies across different contexts, such as self-employment, Deaf and Disabled People’s Organisations (DDPOs), charities, and businesses of varying sizes, from small enterprises to multinational corporations.
To be successful, conversations with employers about reasonable adjustments requires Access to Work staff to be skilled, knowledgeable, and able to have persuasive nuanced conversations. Feedback from employers is that this is currently not the case. We recommend that ATW establish an ‘Independent Adjustments Advisory Service’ supporting employers and ATW customers. This would support the recruitment and development of staff with appropriate skills and, as the goal of the conversation is no longer for the adviser to reduce Access to Work costs, facilitate a more honest and useful conversation. Employers report that these conversations are currently often not dealt with well.

Reasonable adjustments also need to be looked at broadly and not just from the perspective of the adjustment that Access to Work is or may be funding. E.g. with deaf BSL users employers make some or all the following adjustments: reserving desk space for a face to face interpreter, considering seating position and lighting, ensuring there aren’t back to back meetings, using a more accessible video conferencing platform, not requiring the member of staff to take minutes at meetings, etc.

We recommend making ATW a legal entitlement (while remaining needs-based) to ensure consistent access to support.

16. How can we better define and utilise the various roles of Access to Work, the Health and Safety Executive, Advisory, Conciliation and Arbitration Service and the Equalities and Human Rights Commission to achieve a cultural shift in employer awareness and action on workplace adjustments?
To achieve a cultural shift in employer awareness and action there needs to be a coordinated multi-pronged approach.

This would include;
•Access to Work provision that is able to support deaf and disabled people in the workplace in a way that increase employer confidence
•Better and more accessible resources for employers and deaf BSL users
•In person guidance for employers on reasonable adjustments
•A sustained communications campaign
•Exemplar materials and case examples showing how the threshold of ‘reasonableness’ varies across different contexts
•Research of deaf and disabled people’s and employers’ experience, and that allows for a granular understanding of changes in employment
•Monitoring
•And proactive enforcement action that does not rely on individuals to take action.

Access to Work should maintain its current core role of supporting deaf and disabled people to work.
All organisations should contribute condition-specific advice for employers about implementing appropriate reasonable adjustments in the workplace The UK Government's ambition to support disabled people in gaining and retaining employment requires proper resourcing of the Equality and Human Rights Commission (EHRC), and may require legislative changes, so that it can better proactively investigate and act, contributing to the development of case law around reasonable adjustments.

There should also be cross-agency collaboration protocols, for example, so that when Access to Work identifies an employer failing to meet reasonable adjustment duties, EHRC and ACAS are notified and are able to follow up.

The caveat to all of this is that even if this is handled well, if employers believe there is more risk to employing a deaf person and getting the reasonable adjustment ‘wrong’, then the perverse incentive is to avoid that risk by not employing a deaf person in the first place.
For this reason, changes should always be piloted and evaluated before rolling out across the UK.

17. What should be the future delivery model for the future of Access to Work?
We strongly recommend that Access to Work should not be outsourced, as this typically diminishes accountability while increasing costs and/or reducing service quality.

We recommend that neither ATW nor its funding are embedded within Local Authorities, given their severe budgetary pressures and constraints which frequently limit them to providing only statutory services.

Regardless of the future delivery model chosen, it needs to be collaboratively designed with stakeholders, including deaf-led organisations, Deaf and Disabled People's Organisations (DDPOs), ATW service users, and employers representing all sizes of business.
In our view, ATW and its users would be best served by a co-delivery model where a significant proportion of staff possess lived experience of disability. Consideration should also be given to some degree of regional decentralisation to provide more locally focused support. While we believe the fundamental principles and structure of Access to Work are about right, improvements should focus on delivering a more tailored, efficient and cost-effective service that meets needs first time for both disabled people and employers.
Our evidence shows that deaf BSL users frequently encounter ATW advisers and case managers who lack understanding of their specific requirements, leading to incorrect decisions and unnecessary delays. We therefore strongly advocate for the inclusion of disability-specific employment specialists, particularly those specialising in supporting deaf BSL users, within ATW's future operating model.

To ensure deaf BSL users receive appropriate support through Access to Work, the system could allow individuals or their employers to choose their assessor from a specialist pool. This pool would include professionals with expertise in various disabilities, particularly those that are less well-understood, such as deafness. These specialist assessors would provide tailored advice on workplace adjustments, helping to bridge the gap in understanding that many deaf applicants currently face during the assessment process. Access to Work should also develop an internal team of disability specialists within Access to Work itself. These staff members would possess specific knowledge about conditions like deafness and deafblindness and could be matched with applicants accordingly. For individuals with multiple disabilities, specialists could collaborate to ensure all needs are properly addressed. Moving to a delivery model which involves disability employment specialists should and could by design increase the number of staff with lived experience of a disability and/ or health condition. Implementing either or both specialist models would significantly improve assessment quality by ensuring they're conducted by professionals with deep understanding of specific conditions.

As emphasised in our response to question 14, we remain firmly opposed to any reductions in current support levels for deaf BSL users through the scheme or increases in employer contributions. Access to Work must continue to fully fund the existing range of support. Requiring employers to contribute more towards Access to Work support costs and failing to properly resource an ATW system already struggling with delays may perversely increase barriers to employment for deaf BSL users, undermining the scheme's and UK Government’s objectives. Maintaining ATW funding for high-cost support remains critical, as expecting employers to cover these substantial costs will usually be unreasonable. Full access to this financial support is fundamental in enabling deaf BSL users to successfully secure, maintain and progress in employment. Consideration must be made for future budget increases to account for inflation and other market forces to cover real support worker costs and allow for flexibility within award periods for clients to secure the most appropriate support. Flexibility needs to also be built into the system to allow for in-award changes to support requirements and allow for deaf employees to pivot their support to alternative supply where local issues affect their access to personnel

Written by Darren Townsend-Handscomb with input from ASLI membership.