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Mandatory reconsideration - LCWRA

7 replies

SpidersAreShitheads · 29/12/2023 00:24

Hi,

Just after a bit of advice from anyone who knows more about the process of appealing a decision.

DP went through a phone-based assessment and was found to have LCW but wasn't awarded the higher category of LCWRA.

We've looked through the 15 descriptors and he doesn't explicitly fulfil any one of them which felt a bit surprising as he's got very significant medical issues but as the GP said, the DWP set the bar very high!

Apparently there's another way you can be awarded LCWRA which is when it would "cause substantial harm" not to be placed into this category. DP is unlikely to be fit to return to work ever again - he has an unusual neurological condition (tentative diagnosis only at present) which causes a myriad of symptoms and means there's no category of work that he could reliably do. He's only 40 and previously had a great career in IT so it's all been a bit of a shock really over the last 15 months. Both the GP and the specialist have told him to focus on trying to achieve a basic quality of life and not to look any further ahead than that.

So we sent the appeal in via our online UC journal detailing how he meets the criteria for "substantial harm" and today we've got a message saying DP has an appointment with a work coach to discuss this further.

How can a work coach discuss a medical decision? AFAIK they're not medically qualified in any way - and this is backed up by some truly ridiculous comments made by previous work coaches while we were waiting for the assessment.

Is that how a mandatory reconsideration usually works - an interview with a work coach?? I would have expected the case to have gone to a decision maker. Can anyone advise please?

OP posts:
Doggymummar · 29/12/2023 00:52

What is lcwra?

SpidersAreShitheads · 29/12/2023 00:54

Doggymummar · 29/12/2023 00:52

What is lcwra?

Limited capacity for work and work-related activity.

DP has been found to have limited capacity for work - LCW - but not the higher category of LCWRA.

OP posts:
Babyroobs · 29/12/2023 10:57

I thought substantial harm was more to do with mental health but may be wrong.
I don't actually think they do set the bar that high, absolutely most people I help with these forms get awarded LCWRA pretty easily, I have very few awarded LCW, I rarely have to appeal one hence I don't know much about the appeal process tbh. Recent news has told us that the process is changing though in 2025,so maybe they are getting tougher.
Work coaches aren't qualified as far as I know to discuss this. the decision on a work capability decision is made by the assessing people by a doctor usually for work capability. It will not be the decision of his work coach, although they can adjust work search requirements accordingly. I suspect this appointment he has been sent is to discuss what he needs to do to meet UC commitments now he has been awarded LCW. The MR for the decision can take up to eight weeks to be looked at and if you need to take it to tribunal it can take even longer.
Definitely appeal it, if you didn't send medical evidence with the form the first time then try to send as much as possible. Most appeals win I believe. Good luck.

Babyroobs · 29/12/2023 11:06

Also remember that the work capability decision will be looking at whether your dh can do any type of work, not necessarily the type of work he did before he became ill, so they may expect him to look at a less stressful or demanding type of work if able, not easy I know. this is of course if he doesn't get the decision overturned which hopefully he will.

SpidersAreShitheads · 29/12/2023 16:00

Hi @Babyroobs - thanks so much for responding. I've seen some of your other posts so I'm really grateful for your advice.

Re the descriptors - it seems to me that there's so many conditions which could potentially fall down the middle. Descriptors 1-5 are all about mobility but none of them check the ability to bend, kneel, turn your head, look up or look down. Descriptors 6-7 are about communication, 8 is about bladder problems, 9-14 are cognitive/mental health and 15-16 relate to chewing/eating.

DP has struggled with dizziness for 10-15 years and has a couple of collapses putting him in hospital for about a week. No diagnosis was ever reached but serious stuff like tumours etc excluded. Fast forward to September 2022 and he suddenly collapsed at work with excruciating pain in his head and horrendous dizziness which put him in bed for over a week. We've seen neurology, ENT, vestibular physio, and regular physio. So far the diagnosis is vestibular migraines, a visual processing disorder and they have a working diagnosis of PPPV (which is a chronic disorder causing daily dizziness and fatigue - covered by ENT and neurology).

I used to work as a health claims assessor for a private insurance company so I am luckily familiar with the process of being assessed for different categories of work. I don't know much about the current DWP process though but I did assume that it would mean all categories of work, not just his previous.

Neurology have been very explicit - he cannot return to any work with screens and he should avoid them entirely (which honestly is proving to be an absolute bastard). He can't drive because of the flickering lights and the dizziness. And he can't do any job where he has to turn his head, bend, or look up or down.

In addition, his symptoms are daily and vary in intensity - he might feel OK for a couple of hours in the afternoon, he might feel OK for about 4 hours. Or he might be totally out of action all day long. It's really shit tbh. The consultants are basically saying this is the nature of PPPV and to just avoid triggers and try to manage what he can to achieve a quality of life between attacks. He takes heavy duty drugs which make the mornings difficult and if he has to take more because of an attack during the day, he'll be asleep for several hours as they're a strong sedative type.

I can't see how he meets any of the descriptors but his condition is just so, so disabling. I can't see how he could fulfil any category of work because there's so little he can do safely and without exacerbating an attack.

We didn't send in any medical evidence so we'll add that, thank you. We have letters from various specialists supporting all of the above.

We asked for mandatory reconsideration on the journal and got a reply that said "I will book you in for an appointment with a work coach where you can discuss this further." We have been unlucky with some of the work coaches we've seen - a couple of them have been real arses. And the bright lights in the centre will bring on an attack for DP so we would really rather avoid going in unless it's absolutely essential for the MR - which it doesn't seem to be. It feels as if they've just ignored the MR request and booked him in to discuss what work-related activities he could do?!

Re the substantial harm argument, I found some really useful stuff online - it's sort of mental health related but not exclusively so. It's along the lines of "if you have to comply with work-related activities and it puts you at risk of exacerbating your condition, or if you weren't able to comply with work related activities and it means that you wouldn't meet the UC requirements then you should be put in the LCWRA group". I'll find the link where it explains it better.

OP posts:
SpidersAreShitheads · 29/12/2023 16:35

@Babyroobs - this is what one of the advice pages said re substantial risk:

"Substantial risk*
If you do not get 15 points or more, you can still get the benefit if you can argue that there is a risk that you (or someone else) would be in danger if you were refused. For example, if you have seizures, violent outbursts, frequent falls, or need supervision to stay safe, you could argue it would be dangerous for you to work or have to travel to a job without help. Or if you have poor memory or confusion, and would be unable to meet the requirements to receive Jobseeker’s Allowance (or Universal Credit on the basis that you are looking for work), you could argue that there was a substantial risk that you wouldn’t be able to feed or care for yourself. If looking for a job or going to work is likely to make your condition worse or risk you having a relapse (for example, if you are a recovering addict, or have a condition like Chronic Fatigue Syndrome or Long Covid), then that too can be counted.

Similarly, if you have been put in the work-related activity group but it is fairly clear that you could not manage to reliably do the work-related activity you would have to do to keep receiving the benefit, you could argue that there is a substantial risk of harm to you if you were not put in the LCWRA group.
The risk counts as ‘substantial’ if it cannot reasonably be ignored. When judging if the risk is substantial, the DWP or appeal panel are supposed to judge both the likelihood of something happening and the potential seriousness if it does happen. So it is possible to argue that although the likelihood is not big, the consequences would be very bad and therefore the risk is 'substantial'.

Lots of people with mental health problems, cognitive difficulties, Chronic Fatigue Syndrome, Long Covid, or conditions that are much worse on some days than others get ESA this way.

It is always worth raising a potential substantial risk if you can, as it allows the appeal panel to use their common sense."*

https://www.advicenow.org.uk/know-hows/universal-credit-work-capability-assessment-descriptors-activities-and-substantial-risk

I'm hoping that the substantial risk argument would cover DP as there's no way he can safely do any work-related activity with the limitations he has.

We've put a note on the journal querying the reason for the appointment with the work coach because it feels a bit like a pointless trek in. If they want to talk about what work related activities they expect him to do, that's fine, but the implication from their wording is that the appt has been made because he's requested MR which just seems wrong.

Universal Credit work capability assessment - descriptors, activities and 'substantial risk'

If you are entitled to Universal Credit on the basis of having limited capability to work you are put into one of two groups - the Limited capability for work group (LCW) and the Limited capability for work-related activity group (LCWRA).  Which one yo...

https://www.advicenow.org.uk/know-hows/universal-credit-work-capability-assessment-descriptors-activities-and-substantial-risk

OP posts:
Babyroobs · 29/12/2023 18:22

You are definitely doing the right thing by asking for an MR.
Do you have the assessors report ?
Make sure you send copies of all the reports you have from various consultants.
It sounds like a horrendous condition, hopefully their decision will be overturned. Lots of MR's / appeals are won on the substantial harm descriptor I believe. Ironically this is the descriptor they are talking about removing in the future if the new proposals go through😫

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