The following guidance is provided for those who prefer to copy, adapt, or expand on suggested responses. Please note that responses to the consultation need to be received before 30 June 2025 before 11.59pm.

See our Nub post on where to send your responses.

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Guidance for members

The government suggests in the green paper that it cannot meet all of the current and future demand on Access to Work (AtW), so it has to change something.

It is crucial that Deaf Customers, Deaf & Disabled People’s Organisations, Deaf ATW, the National Union of British Sign Language Interpreters and Translators (NUBSLI) and the professional associations representing Sign Language Interpreters and Translators should be actively involved in this review and change process for AtW.

It is through genuine collaboration that government is most likely to address the problems, build a resilient AtW that is fit for the future, and support its goal of supporting more deaf and disabled people in the workplace.

DWP should be striving to set an example and avoid doing anything that ultimately prevents access and undermines the whole ethos of AtW that employing a deaf or disabled person should not involve additional costs to the employer.

Similarly, any attempts to push the full costs of workplace adjustments onto employers with a large workforce should not be applied in the same way to self-employed deaf or disabled people. No proposals should put the responsibility of enforcing reasonable adjustments on the Deaf Customer.

There appears to be no reference in the green paper to evidence that employers are unaware of their obligations to provide workplace adjustments, rather than simply not wanting to pay out for them.

It is a barrier to the employment of deaf and disabled people, when employers can choose a non-disabled employee over a disabled candidate as a cost saving. AtW is there to ensure that employing a disabled person has no cost implications to an employer. 

AtW customers’ contribution to the economy and society should be recognised. Recipients pay tax on their income, and they should be treated with dignity and respect. 

13. How can we support and ensure employers, including Small and Medium Sized Enterprises, know what workplace adjustments they can make to help employees with a disability or health condition?

The Commission on Social Security (Steering Group) —a group led by Deaf and Disabled people—has carried out extensive research into benefit reform, including examining models used in other countries. Engaging with them could offer valuable insights into how to create more inclusive and effective support systems.

One of the challenges is that Access to Work (AtW) users who require high-cost support, such as British Sign Language (BSL) interpreters, represent a small percentage of customers but account for a significant portion of the overall budget (source). While that in itself is not inherently negative, there is concern that this might trigger cost-cutting measures, rather than informed, inclusive reform.

Employers will need to be meaningfully incentivised to make adjustments—because without incentive or enforcement, some employers will simply choose not to hire Deaf or Disabled people at all. This is especially true for small and medium-sized enterprises (SMEs), who may be unsure of what’s expected or concerned about costs.

Where employers can afford to contribute to support—particularly larger companies—they should be encouraged to do so. However, enforcing this across the board risks unintended consequences.

If employers are required to bear the costs of interpreting or other adjustments without proper support, Deaf people may become viewed as “unattractive hires,” whether new or existing staff. This could lead to a change in recruitment behaviours, especially among profit-driven private companies.

Employers can and should be encouraged to implement inclusive practices beyond just funding interpreters—such as improving workplace accessibility, inclusive communication strategies, and fostering an inclusive culture. While these are helpful, they do not replace the need for qualified interpreting and other formal adjustments.

Under the Equality Act, employers are already required to provide reasonable adjustments—but without proper monitoring and enforcement, this obligation often has limited real-world impact.

If any future reform proposes that employers take on more of the cost burden for adjustments, this must be co-developed with both employers and ATW customers. It must be piloted, evaluated, and accompanied by adequate resources within DWP to monitor compliance and take enforcement action where necessary.

No change should ever place the responsibility of securing or enforcing adjustments onto Deaf or Disabled individuals themselves.

Recent leaks on social media suggest that changes to the scheme may be progressing before consultations are concluded. Any reforms must be transparent, inclusive, and co-produced—in collaboration with the BSL Advisory Board, stakeholder groups, representative organisations, employers, and Deaf and Disabled customers.

Reform done with the community will lead to progress. Reform done to the community will only cause harm.

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?

To maximise the impact of a future Access to Work (AtW) scheme and ensure it truly works for Deaf people, the Department for Work and Pensions (DWP) must continue to directly fund core communication support, while also investing in better systems, awareness, and accountability. Without this, AtW risks becoming harder to access, especially for BSL users.

The DWP should directly fund the following for individuals:

• BSL interpreters and communication support workers – This must remain fully funded by DWP. Shifting costs to employers will only result in fewer Deaf people being hired, or having reduced access once in work.
• Remote interpreting platforms and support – Flexible access to interpreting services (including VRI/VRS) is essential, especially in hybrid or remote workplaces. This should not replace face to face interpreting support where needed.
• Note-taking, captioning, and speech-to-text services – These are vital for Deaf professionals who need multiple forms of support depending on context.
• Support with AtW administration – The current process is complex, inconsistent, and inaccessible for many Deaf people. DWP should fund admin support or caseworkers to help Deaf applicants manage claims and renewals.
• Appeals and complaints support – Many Deaf people feel they don’t have the confidence or language access to challenge poor decisions. This must be funded and made accessible in BSL.

What DWP should support for employers:

• Incentives for inclusive hiring – Employers need financial and practical encouragement to hire Deaf people, especially in industries where adjustments are wrongly seen as a burden.
• Education and training grants – Employers must understand the legal and practical aspects of employing Deaf people, including Deaf awareness, working with interpreters, and inclusive communication.
• Sector-wide solutions for interpreter access – For example, pooled interpreting budgets or shared interpreting staff across teams or locations could help normalise support and reduce admin.
• Access coordinators or specialists – Larger employers could receive support to hire access officers who ensure Deaf staff consistently get what they need.

Key points for DWP to remember:

• BSL interpreting is not optional—it is a legal and practical requirement, and DWP must guarantee it is funded and available when needed.
• No part of this should be pushed onto the Deaf employee to fight for or enforce—DWP must lead on monitoring and holding employers accountable.
• Nothing about us without us—Any reforms must be co-designed with Deaf people, including Deaf-led organisations and the BSL Advisory Board. That includes pilots, trials, and decision-making at all levels.

Deaf people face huge barriers getting into and staying in work. A future ATW scheme can be transformational—but only if it’s built with the Deaf community and Sign Language Interpreters.

15. What do you think the future role and design of Access to Work should be?

AtW should be needs-led and support to the highest need.

The government should not try to support more people by reducing support to those with most need. It is intended to be a holistic discretionary award which meets whatever an individual’s needs are in the workplace – not minimum need.

AtW support beyond entering the workplace.

AtW needs to support people to thrive and get on in their jobs in addition to supporting them to enter the workplace. Employers will be more confident to recruit further disabled employees if they see disabled individuals being successful.

Accessible application process.

Specialist knowledge about Deaf Customers’ needs within AtW Telephony teams, Advisers and Case Managers.

High quality paid training from people with lived experience of disability is essential for AtW staff to understand the needs of applicant and customers. 

Staff awareness of the range of Deaf Customers whose first, or preferred, language is British Sign Language, particularly highlighting that English is a second – or, in some cases, third or fourth – language for the majority of Deaf Customers, so the subtleties of the questions and the detail of the answers required in the ‘Support Worker Record of Tasks’ will present a challenge for many deaf people and, being that the majority of Support Worker (SW) tasks for deaf applicants will be communication-based, listing the number of hours per week that a Deaf customer might need to communicate with their colleagues via a Sign Language Interpreter is impossible to quantify on a SWROT form.

Reintroduce Specialist Assessors

Employing or commissioning Specialist Assessors who have lived experience of deafness and/or working in partnership with organisations who have specialist knowledge and experience of disability and being an AtW customer could support those applying for & renewing AtW awards to get a package in place that meets their needs in the workplace, rather than being disadvantaged by an application/renewal process requiring a standard of English literacy that many deaf applicants will struggle to meet, which sets them up to fail.

Make the AtW workforce more reflective of the community it is there to support.

• Actively recruiting a diverse workforce of Telephony Agents, Advisors, Case Managers and Compliant Handlers, including staff with a range of disabilities, would increase opportunities, awareness and empathy within the Service Centre teams.   
• Appropriate support for those not in standard full-time employment.
• The process needs to be made more accessible for freelancers, part-time workers and people in non-traditional employment. Assessors need to understand the nature of self-employment and how freelance individuals work and run their businesses.

AtW to offer emerging Tech & ATech solutions to customers, separate from their AtW awards.

Make transcription software available at no charge to customers.

For Deaf Customers who do use English in the course of their work, a good quality transcription software could be made available to anyone on the AtW scheme that does not come out of their award. English transcription products can be useful to some people, so these could be evaluated for accuracy and bulk purchased to reduce the cost of provision.

Government to fund a Video Relay Service (VRS) that is free to customers.

Remote sign language interpretation will never replace face-to-face interactions with colleagues and clients with an interpreter present who works regularly with the customer and has contextual knowledge of their job role; however, to enhance access & allow for ad hoc communication which would resolve a lot of barriers, the government could fund a universal VRS, as it has with Contact Scotland, that is free at the point of use for the Deaf Customer.

DWP to focus on & fund AtW as a separate entity to meet current and future demand.

• An increase in fully trained staff focused on AtW alone to better meet demand, rather than seconding staff from UC/PIP teams who are not experienced in the specifics of AtW, so that awards and payments can be made on time by an appropriately funded and dedicated resource.
• AtW needs to be resourced adequately. According to the DWP’s own figures, it is currently only funding support for 1.12% of the disabled workforce. With the government’s proposed reforms to PIP, and its stated intention of encouraging more disabled people into work, DWP needs to have the resources in place to cope with potentially 100,000s of additional requests for workplace adjustments?

Clarity over how a customer’s award and hourly rate has been calculated.

• There are inconsistencies in awards and support agreed across different regions and sectors, which needs to be addressed.
• Possible removal of the hourly rate for Support Workers and simply allocating a total amount to the customer to cover the award period. The hourly rate could still be included in the award letter but make it clear that it is simply a guide to enable customers who are concerned about overspending to budget effectively for the period of the award.

Customer choice & control over their support is paramount.

If the Deaf Customer wants to book a particular Support Worker for a one-off evening booking or book a second Sign Language Interpreter to co-work a training session, and the SW’s fees are not covered by the customer’s hourly rate, if the customer has the budget available, they should have the choice as to who they are supported by as long as they are mindful that their budget has to last for the duration of the award period.

The danger is that blanket services will become a barrier to meeting individual needs. Flexibility needs to change. Some people need additional support only at certain times of year, or for specific training or events that they may have been unaware of at the time their AtW award was agreed, so if they book 2 x interpreters they risk their award being overspent.

Training for new customers & budget management tools for all.

Training should be made available for customers who are new to AtW and this should be available in BSL. Budget management tools should be available to all customers, regardless of how long they have had an award in place.

Remove the cap on a customer’s award.

AtW support should be needs-based, with individuals receiving the funding they require to participate fully in the workforce, without arbitrary financial limitations.

The AtW cap creates unnecessary barriers to employment and prevents individuals from getting the support they need to work. It is insufficient to meet the needs of many disabled people, particularly those with complex needs. Whilst there is no suggestion that a blank cheque should be issued to customers, the cap can prevent people from accessing the support they need to start a job, stay in employment, or progress in their careers.

Allocate separate budgets based on individual needs. Focus on the adjustment required, not the disability.

In the current process, the cap is the cap. Therefore, if two Deaf Customers have the same communication support needs that would lead to their award being capped, i.e. both require full-time Sign Language Interpreters, but one of them has multiple disabilities that require additional support or specialist equipment in the workplace, etc. this would have to come out of the same budget, which could force them to use fewer support hours for interpreting, use Trainees instead of Registered Sign Language Interpreters, or not have their other support needs met in order to stay within their capped award. 

There is a case here for allocating separate budgets based on the workplace adjustment(s) required, rather than a single capped award from which an individual might struggle to meet all of their needs.   

Reintroduce ‘light touch’ renewals to reduce backlogs & save time for both AtW staff and Deaf Customers.

Once deafness has been established by AtW as an applicant’s main disability, most Deaf Customer’s support needs are unlikely to change throughout their working life. Obviously, there will be changes of circumstance for some customers, but if the claimant states at their 3-year renewal that they require like-for-like support going forwards, there should no need to do a full reassessment of their needs.

Save time by reducing regularity of renewals, particularly for capped customers.

Capped customers should not have a detailed review annually if they state that their support needs have not changed.

All renewals should be no more regularly than every three years, possibly less, unless there has been a change of circumstance.

Removal of requirement for Support Worker quotes.

Remove the need for 3 x Support Workers quotes from Deaf Customers whose only support need is Sign Language Interpreters. NUBSLI’s Fee Guidance for Freelance BSL/English Interpreters is publicly available on its website and is updated regularly. AtW’s Service Delivery and Policy Teams are aware that this is the case and NUBSLI is happy to work with DWP on this. 

Support Worker fee quotes should only be requested if the Deaf Customer reports that their Support Worker fees exceed those quoted for their region in the NUBSLI Fee Guidance.

Sign Language Interpreters are usually self-employed freelancers, so any SW fee benchmarking should be based only on freelance rates (i.e. NUBSLI Fee Guidance), not salaried rates.

Investment in improving DWP’s IT infrastructure.

Provide transparency about claims processing backlogs.

The introduction of the online claims portal was a gamechanger for Deaf Customers in terms of ease of submitting a claim and also for their Support Workers whose invoices were initially being paid well within AtW’s stated aim of 10-days of a correctly completed claim form being received.

This was evidence of what is possible and that the system really can work in a timely manner. However, the public-facing phone message announcing the timescale for processing claims has been doubled to 20 days in recent months. We are told this is due to an increase in applications and a change in the behaviour of existing customers (making multiple claims per month instead of just one).

The increasing delays in Support Worker payments has resulted in an increase in calls to AtW by customers & Support Workers chasing payments. Aside from the waste of Deaf Customer and Support Worker time waiting to get through to a Telephony Agent, it also takes up a lot of AtW staff time that could be put to better use processing claims or dealing with more complex phone enquiries.

Being transparent about the backlog would reduce the amount of time Telephony Agents spent dealing with repetitive enquiries about the same thing and also enable customers and Support Workers to get the answer they want without spending an hour trying not get through to someone.

Simply update the outgoing voice recording on a daily basis to something like, “We aim to pay claims within 20 working days of receiving a correctly completed claim form. We process claims in strict order of date of receipt and are currently working on claims received on [insert date/month]. If you have a query about a claim before that date, or anything else, please stay on the line.” 

Enable Support Worker log ins to online claims portal.

Another measure that would save time for all concerned would be for AtW to view Support Workers as its customers too and to enhance the portal to include a log in for Support Workers to check the status of their invoices and payment history.

Obviously, access would have to be limited to their own invoices and payments, so they would not have access to the customer’s data or personal details about other Support Workers or their payments.

All Support Workers have a Payee Reference Number on their remittances from SSCL, so perhaps this could be used as a log in if an AtW URN could not be generated for each Support Worker.

Invest in one seamless IT system.

The current systems operated within AtW consist of an online portal which is, essentially, a dumb terminal that does not link to anything, then claims are processed via two further old and creaky computer systems for processing before being passed through to SSCL for payment to be issued.

None of these systems talk to each other, which is a frustration for staff and customers alike, and creates a barrier to efficient processing of applications, renewals, changes of circumstances, complaints and reconsiderations.

Upfront investment in a new system or a serious overhaul of the current IT infrastructure would result in long-term benefits of a more efficient and seamless process for all concerned.

Clarity around ‘budget remaining’ figure stated on the portal.

The ‘budget remaining’ figure on the online claims portal is a good idea but it needs context because simply showing one figure is misleading to customers and can leave them at risk of overspending their award.

It should be made explicit that the figure does not include deductions for Support Worker claims not yet invoiced or paid. Ideally, the portal would be updated to show a ‘live’ figure for remaining budget, specifying the last date that it was updated & indicating any submitted claims that have not yet been processed or paid.

Reduce admin for customers & allow admin to be delegated to a nominated 3rd party.

The current approach of giving awards to individual customers for them to manage is the right one. However, there is a huge amount of work for Deaf Customers to do in administering their award which takes time away from their day job.

Ideally, system reforms to reduce the amount of admin required by customers would be ideal. In the meantime, the award should continue to be allocated to the Deaf Customer but if it is their choice to nominate a third party to administer the award on their behalf, they should be able to do so.

AtW to fall within AME

Access to Work should fall within Annually Managed Expenditure (AME), the category of government spending that includes welfare benefits and other payments that fluctuate based on factors like economic conditions and individual circumstances.

However, it is currently managed as a separate entity and not as part of the broader AME as it is judged to be a targeted programme with specific eligibility criteria and funding levels, rather than a broad, automatically adjusting expenditure.

Pay Support Worker travel.

As the majority of AtW awards include no separate element for travel, rather than forcing Support Workers to include their travel with their fee – which can lead to all-inclusive fees that exceed the customer’s hourly rate – AtW should pay SW travel (public transport at full cost & mileage at 45p per mile) from a separate budget that does affect the customer’s award.

VAT

Remove VAT from the hourly interpreting rate because this is unfair.

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?

While members of the National Union of British Sign Language Interpreters (NUBSLI) may not have detailed insight into how all of these organisations (Access to Work, the Health and Safety Executive, ACAS, and the EHRC) currently work together, we can speak to how they could better support Deaf employees and BSL users.

The Equality and Human Rights Commission (EHRC) must be properly resourced and empowered to monitor and enforce compliance with the Equality Act. At the moment, there is very limited accountability when employers fail to provide reasonable adjustments, and this disproportionately affects Deaf employees who require BSL interpreting.

The Access to Work scheme should be seen not just as a funding mechanism, but as a vital part of embedding inclusive employment practices. It could play a stronger role in educating employers, particularly SMEs, about what Deaf-friendly workplace adjustments look like, including how to work effectively with interpreters and other communication professionals.

The way DWP engages with the Health and Safety Executive (HSE) and ACAS could help promote consistent standards around inclusive practices. For example, clearer guidance could be developed around communication accessibility as part of workplace health and safety, especially in high-risk or fast-paced environments where visual communication is essential.

While we recognise that detailed coordination between these bodies is beyond NUBSLI’s remit, we strongly recommend that any efforts to drive cultural change must include Deaf people and BSL users from the start, and be developed in partnership with representative organisations. Without that lived expertise, well-meaning initiatives may fall short in practice.

17. What should be the future delivery model for the future of Access to Work?

Bring in expertise and collaborate rather than outsource. 

Provide specialist knowledge within the staffing of AtW:

• Specialist roles, as was previously the case
• High quality training from people with lived experience – live and a recorded resource bank
• In-house paid partnerships working with knowledgeable organisation like DDPO’s

Outsourcing risks: 

• Private companies are profit driven
• Subcontracting would reduce the remuneration to the end supplier or result in deaf peoples’ awards being insufficient to cover support for the period awarded

• All relevant stakeholders should be consulted in any new proposed delivery model – e.g. Deaf people, the BSL Board, Interpreter union NUBSLI and Professional Organisations ASLI, VLP.
• Support workers (BSL interpreters) are freelance and so benchmarking needs to be done on these rates not salaried rates
• Focus on support need categories, e.g. mobility, communication, rather than type of disability. Sub-categories that focus on the adjustment not the disability.
• Award a budget allocated to individuals with the employer (or if self-employed, a chosen third party) managing it for them.
• Establish an application system that is straightforward and accessible for deaf people. (e.g. The ‘Support Worker Record of Tasks’ at the point of application is inappropriate for a deaf person, as communication needs can happen at any time during their working day/week.)
• The old and ineffective digital infrastructure is not fit for purpose and a barrier to efficiency – it is unable to harness technological advancements, including AI, which can provide more automation, ultimately saving money.
• Proper investment to data and digital delivery through an effective portal that will allow deaf people to self-serve. Better data collection would allow AtW to develop in a way that is fit for purpose.
• A start to end function where individuals can apply, receive a budget, manage their budget effectively (so that real time information about the remaining award is clear) and process their own claims etc. Would reduce administration and save money. 
• Real time information about an individual’s award through the portal = less need for phone contact.
• Providing budget management tools, training for people new to AtW, etc. something
• that can result in more efficient use of resources.
• Despite the claims of invested companies, the current AI technology, as it exists, is by no means able to replace the work of BSL Interpreters or Communicator guides. 
• Some transcription products can be useful to some deaf AtW customers and – following an evaluation for accuracy – could be bulk purchased for use.
  

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Inclusion London has also provided recommendations on improving Access to Work – you can read their report here (PDF).

If you intend to respond to the consultation, you will find our ‘cheat sheet‘ on how to respond useful. View the guidance here.