The following ‘cheatsheet’ is to provide you with a guide on how you might want to respond to the consultation. You can expand on these talking points or add your own experiences in your response.
Important: the deadline for responding to the Government’s consultation is 30 June 2025 at 11.59pm. See our Nub post on where to send your responses.
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?
- Engage with the Commission on Social Security (Steering Group) led by Deaf and Disabled people, using their research on benefit reform and international models.
- Employers must be meaningfully incentivised to make adjustments. Without incentive or enforcement, some may avoid hiring Deaf or Disabled people—especially SMEs concerned about cost or expectations.
- Larger companies employing Deaf people that can afford to contribute to support should be encouraged to do so, however mandatory cost-sharing could have negative effects.
- Risk of Deaf people being viewed as “unattractive hires.”
- Potential shifts in recruitment behaviour, particularly in profit-driven companies.
- Companies could be encouraged to foster inclusive practices beyond interpreters, these practices are valuable, but are absolutely not a substitute for qualified interpreters and formal adjustments.
- As examples, employers could focus on:
- Improving workplace accessibility.
- Fostering an inclusive workplace culture.
- Organizing work schedules as much as possible to make best use of AtW funded support
- As examples, employers could focus on:
- Any AtW reform that requires employers to share costs must be:
- Co-developed with employers and ATW users.
- Piloted and evaluated.
- Backed by adequate DWP resources for compliance and enforcement.
- No reform should shift the burden of securing/enforcing adjustments onto Deaf or Disabled individuals.
- There is concern that persons on social media are perporting leaks about changes happening to ATW before the end of the consultation. Reforms must be:
- Transparent.
- Inclusive.
- Co-produced with:
- Stakeholder groups.
- Representative organisations.
- Employers.
- Deaf and Disabled customers.
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?
For a better future Access to Work (AtW) scheme:
- DWP must fund core communication support for Deaf people.
- Improve systems, awareness, and accountability.
- Without action, AtW will become harder to access, especially for BSL users.
DWP should directly fund:
- BSL interpreters and communication support workers – Must stay fully funded; shifting cost to employers will reduce Deaf employment.
- Remote interpreting platforms (VRI/VRS) – Essential for remote/hybrid work; shouldn’t replace in-person support where needed.
- Note-taking, captioning, and speech-to-text – are critical for varied communication needs in different contexts, but can’t always be provided by AI solutions. These will still need human support in certain situations.
- AtW admin support – Current system is complex and inaccessible; fund admin help or caseworkers for ATW budget holders
- Appeals and complaints support – Must be accessible in BSL; many lack confidence or language access to challenge budget allocation decisions.
DWP should support employers with:
- Incentives for inclusive hiring – Financial and practical support to encourage Deaf employment.
- Education and training grants – Covering Deaf awareness, legal duties, interpreter use, inclusive communication.
- Sector-wide interpreter solutions – E.g., shared budgets or interpreters across teams to reduce admin and normalise access.
- Access coordinators/specialists – Larger employers could get help hiring dedicated access officers.
Key points for DWP:
- BSL interpreting is essential, not optional—must be guaranteed and funded.
- Deaf employees should not bear the burden of enforcing access or support.
- “Nothing about us without us” – Deaf people and Deaf-led orgs must co-design all reforms.
- AtW can be transformational—but only if built with the Deaf community and 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.
AtW support beyond entering the workplace.
Accessible application process.
- Specialist knowledge about Deaf Customers’ needs within AtW Telephony teams, Advisers and Case Managers.
- Reintroduce Specialist Assessors
Make the AtW workforce more reflective of the community it is there to support.
AtW to offer emerging Tech & ATech solutions to customers, separate from their AtW awards.
- Make transcription software available at no charge to customers.
- Government to fund a Video Relay Service (VRS) that is free to customers.
DWP to focus on & fund AtW as a separate entity to meet current and future demand.
Clarity over how a customer’s award and hourly rate has been calculated.
Customer choice & control over their support is paramount.
Training for new customers & budget management tools for all.
Remove the cap on a customer’s award.
Allocate separate budgets based on individual needs. Focus on the adjustment required, not the disability.
Renewals
- Reintroduce ‘light touch’ renewals to reduce backlogs & save time for both AtW staff and Deaf Customers.
- Save time by reducing regularity of renewals, particularly for capped customers.
- Removal of requirement for Support Worker quotes.
Investment in improving DWP’s IT infrastructure.
- Provide transparency about claims processing backlogs.
- Enable Support Worker log ins to online claims portal.
- Invest in one seamless IT system.
- Clarity around ‘budget remaining’ figure stated on the portal.
Reduce admin for customers & allow admin to be delegated to a nominated 3rd party.
AtW to fall within AME
Pay Support Worker travel.
Remove VAT from the hourly interpreting rate.
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?
- NUBSLI members may not fully understand how Access to Work, HSE, ACAS, and EHRC currently collaborate.
- However, NUBSLI can advise on how these bodies could better support Deaf employees using BSL interpreting services, funded by ATW.
- EHRC must be properly resourced and empowered:
- To monitor and enforce the Equality Act. Currently, there’s limited accountability when employers fail to provide reasonable adjustments. This disproportionately affects Deaf employees needing BSL interpreting.
- Access to Work should be more than just funding:
- It should help embed inclusive employment practices.
- It should educate employers—especially SMEs—on Deaf-friendly adjustments.
- Include guidance on working with interpreters and communication professionals.
- Cultural change efforts must involve Deaf people:
- Include BSL users and representative organisations from the beginning.
- Lived experience is essential for effective and practical solutions.
- Without it, initiatives may fall short despite good intentions.
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.
Inclusion London has also provided recommendations on improving Access to Work – you can read their report here (PDF).