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The Harrington review

Independent review of the work capability assessment

1. Background

The Department for Work and Pensions met its statutory obligation to review the Work Capability Assessment (WCA) by commissioning Professor Malcolm Harrington to undertake an independent review - The work capability assessment: a call for evidence - and asked organisations and individuals who have information that was relevant to how the WCA is operating to respond. The closing date for responses was 10 September 2010. The consultation applied to England, Wales and Scotland.

There was subsequently a year two and year three review. You can view all our responses to the various stages of the review in the More information section.

Independent review of the work capability assessment

This first review has examined the whole process from the claimant’s initial contact with Jobcentre Plus through to the final assessment, with or without the involvement of the First-tier Tribunal.

The review was published on 23 November 2010, together with the Government's response.

The review makes the following 25 recommendations (the Government response is at the end of each recommendation).

The Government accepts 21 of the recommendations (at least in part). But DA is disappointed that only a quarter of the recommendations seem to be planned to be implemented before people on Incapacity Benefits undergo a WCA from Spring 2011 at the rate of 10,000 per week.

This will leave an ineffective test operational at substantial social and material cost through disabled people not receiving appropriate support, high rates of appeal and an increased role for Jobcentre Plus.

2. Recommendations of the first review

Customer experience

1. The review recommends that Jobcentre Plus manages and supports the claimant during the course of their benefit claim and identifies their chosen healthcare adviser.

Response: Accept
Rationale: The Department recognises the importance of providing support for people throughout their claim process. The IB reassessment journey will specifically address this with additional contacts at the start of the process and at the point of decision. Calls to ESA recipients to explain decisions and as part of enhanced reconsideration measures are also being introduced.
Timing: Support for individuals going through IB Reassessment has commenced in the trial areas and will also be included for national reassessment from early 2011. ESA measures will be adopted across the country by the end of 2010. Further support for ESA recipients at the start of the process will be considered in the light of IB reassessment experience.
Other relevant information: In terms of identifying an individual’s "chosen healthcare adviser", this is about signposting people to areas for help and support, e.g., with completion of the ESA50 questionnaire and emphasising the need to supply additional evidence. Again, Government fully endorses this.

DA says: Some disabled people will not have one healthcare advisor but many. Other disabled people may not even be registered with a GP (many people with learning disabilities and mental health problems are unregistered). DA is concerned that DWP appear to be acknowledging a problem of the WCA but not improving the WCA, instead requiring further Jobcentre Plus actions to address WCA failings. This new activity will use resources we believe should be focused on ensuring the test is effective and disabled people have the support they need to find and keep suitable work.

2. The review recommends that the initial questionnaire (the ESA50) includes a more personalised justification so the claimant can express the issues that they face in a short paragraph.

Response: Accept
Rationale: The ESA50 is an important tool in capturing information about how the functional effects of an individual’s condition affects them, and we are keen to ensure that it gives them ample opportunity to explain this. Therefore we will add a section for a personal justification to the form.
Timing: The revised ESA50 will be in place by Spring 2011 in time for the National rollout of IB reassessment.
Other relevant information: We are currently revising the ESA50 form to make it more user-friendly and to ensure individuals can explain in their own words how their capability for work is limited.

DA welcomes the commitment to improving the ESA50 and extending its use. We hope the Government will be monitoring the use of ESA50s and ensuring disabled people’s health conditions and impairments are appropriately considered in WCAs.

3. In the longer term, the review recommends that the Government reviews the ESA50 to ensure it is the most effective tool for capturing relevant information about the claimant.

Response: Accept
Rationale: We believe that it is essential to give people the opportunity to provide their own written evidence about how their condition affects them and their ability to work. We will continue to keep the ESA50 questionnaire under review to ensure that it captures the most relevant information to support Decision Makers in making accurate decisions.
Timing: Ongoing
Other relevant information: See response to Recommendation 2 about other changes to the ESA50.

4. The review recommends that written communications to the claimant are comprehensively reviewed so that they are clearer, less threatening, contain less jargon and fully explain the process.

Response: Accept
Rationale: We are committed to improving our written communications. Many improvements have already been made to letters and notifications for ESA and IB recipients. In looking to transform written communications we have sought advice from the Simplification Unit at Reading University who are recognised experts in this field. We have also engaged with a number of Customer Representative Groups on a number of letters and forms.
Timing: Revised notifications for IB recipients are being tested in the reassessment trials that commenced on October, prior to introduction nationally from early 2011. Improved decision notification letters for ESA recipients will be available from May 2011.

DA welcomes the provision of better information to people undergoing WCAs and the timeframe for action.

Atos assessment

5. The review recommends that every Atos assessment contains a personalised summary of the assessment in plain English.

Response: Accept
Rationale: We agree that it is crucial that all ESA reports clearly convey the basis of the healthcare professional's opinion on capability for work. All Atos healthcare professionals will receive updated training to provide a robust justification in ESA reports in the year 2010 - 2011. We will also explore the feasibility of providing a personalised summary as part of the ESA report before the end of 2011.
Timing: Updated training in 2010 – 2011.

DA believes all WCA assessors should be appropriately trained. This would help reduce avoidable appeals due to poor assessments. DA is disappointed that the Government is not committing to providing people a full copy of their WCA. A personalised summary will not contain the full information and the Government is only committing to ‘exploring the feasibility’. We await the final decision on feasibility.

6. The review recommends that every claimant is sent a copy of the Atos personalised summary and is able to discuss any inaccuracies with a Decision Maker.

Response: Accept
Rationale: It is essential that the basis of decisions is available and properly explained.
Timing: To coincide with the inclusion of the personalised statement in the Atos assessment above (see recommendation 5).

7. The review recommends that Atos provide mental, intellectual and cognitive champions in each medical assessment centre. These champions should spread best practice amongst healthcare practitioners in mental, intellectual and cognitive disabilities.

Response: Accept - Since May 2011, Atos Healthcare has appointed 60 champions.
Rationale: We recognise that assessing individuals with mental, intellectual and cognitive impairment can be challenging. Therefore DWP and Atos will establish healthcare professionals with enhanced skills as champions who will serve as a resource for all healthcare professionals.
Timing: By the end of the first quarter of 2011.
Other relevant information: As part of its continuing professional development programme in the year 2010 – 2011, Atos Healthcare has produced an additional training module on mental health conditions.

DA understands that each assessor will see 8 people a day and there are multiple assessors in each assessment centre. It is difficult to envisage how one champion of health conditions per assessment centre will answer the over-riding problem of inadequate training for assessors or poor assessments for people with fluctuating conditions in particular.

8. The review recommends that Atos pilot the audio recording of assessments to determine whether such an approach is helpful for claimants and improves the quality of assessments.

Response: Accept
Rationale: Atos Healthcare has provision for the recording of medical assessments and we will shortly launch a pilot initiative to establish the feasibility and cost effectiveness of recording of all face-to-face assessments.
Timing: The pilot will commenced during the first quarter of 2011. These results have now been published.

On 1 February Chris Grayling announced:

"On audio recording, we will offer everyone who wants it the opportunity to have their session recorded. We decided not to implement universal recording because, based on the trial experience, people did not want it. Few people wanted their sessions recorded, and some said that they definitely did not. We decided therefore to offer recording as an option to those who want it." [source Hansard 1 Feb 2012 : Column 292WH]

A number of machines have been purchased to enable recording of medicals. However problems with machine breakdowns have meant that this service cannot be offered in many cases. Currently the DWP still expects Atos to carry out a medical even if there is no recording service available.

DA believes some disabled people will be reassured that they may be able to record their WCA. However, we note that the Government is committed to undertake a pilot – to examine feasibility and cost effectiveness of more widespread recordings. We hope the Government will state how many people will be involved in the pilots and when they will conclude.

9. The review recommends that Atos should develop and publish a clear charter of claimant rights and responsibilities, and should consider publishing the HCP guidance online for claimants and advisers.

Response: Accept
Rationale: The Department is committed to improving the WCA; part of that commitment includes clearer communication to individuals. We will therefore ensure that more information is made available; this will include the development and implementation of a comprehensive Customer Charter from Atos Healthcare.
Timing: During the first quarter of 2011.

DA welcomes a charter and hopes this will include clear channels of communication for complaining about individual assessors.

The decision making process

10. The review recommends that Jobcentre Plus Decision Makers are put back at the heart of the system and empowered to make an independent and considered decision.

Response: Accept
Rationale: The Department is committed to empowering and supporting Decision Makers to enable them to make the best possible considered decisions.
Timing : A new communication forum "Every Decision Counts" is already in place providing Decision Makers with an opportunity to share issues and good practice. A Quality Assessment
Framework will be developed to improve the consistency of decisions and Learning and Development will also be reviewed. These additional support tools will be introduced in 2011.

DA is unclear what this mean in practice but hopes tools are openly available and will be in place as early as possible in 2011. We suspect this partly links to the plan to use Jobcentre Plus staff to call claimants during the process. This duplicates the cost of running a WCA and will result in less DWP resources focused on ensuring disabled people get the support they need.

11. The review recommends a better use of the reconsideration process.

Response : Accept
Rationale: An effective reconsideration stage is an important element of the decision making process. Considerable progress has been made in strengthening the process with the piloting of new measures at Wrexham and we will expand this experience nationwide.
Timing: Changes for ESA recipients have already been rolled out across the country. These will be extended to IB recipients as part of the reassessment process from early 2011.

DA welcomes greater use of reconsiderations if this results in disabled people securing appropriate support at an earlier juncture than the current under-performing WCA process allows. However, we are very concerned that this avoids improving the WCA – instead focusing on improving initial decisions before a formal appeal. There are avoidable costs involved and we believe the focus should be on developing a better WCA and greater support for disabled people to get and keep jobs.

12. Decision Makers are able to seek appropriate chosen healthcare professional advice to provide a view on the accuracy of report if required

Response: Accept
Rationale: Decision Makers should seek appropriate advice and/or additional evidence in coming to their determination if they require. Different approaches, e.g., with Atos healthcare professionals providing advice and support in interpreting evidence on site through case consultations or "surgeries" and or workshops/training events, are currently being trialled.
Timing: Agreed measures will be adopted nationally during 2011.

DA is concerned that the timeframe for action risks 10,000 people starting to undergo the WCA per week before the system is functioning better.

13. Better communication between Decision Makers and Atos healthcare professionals to deal with borderline cases

Response: Accept
Rationale: Decision Makers already contact Atos healthcare professionals to discuss individual case issues in some instances. As with recommendation 12 above we will ensure this happens more often.
Timing: Agreed measures will be adopted nationally during 2011.

DA welcomes greater communications if this improves the current system which is failing to appropriately support disabled people. 

14. Decision Makers receive training so that they can give appropriate weight to additional evidence

Response: Accept See recommendation 10 above.

The appeals process

15. The review recommends that tribunal decisions are better monitored, including monitoring of the relative or comparative performance of tribunals.

Response: We will consider this recommendation, which is the remit of the First-tier Tribunal.

DA is very concerned that these three recommendations appear to undermine the independence and authority of the Tribunals and await final consideration.

16.The review recommends that training offered by the Chamber President to Tribunal Judges and medical Members should include modules on the evidence of the beneficial effects of work to an individual’s well-being.

Response: We will consider this recommendation, which is the remit of the First-tier Tribunal.

17.The review recommends that feedback from the First-tier Tribunal should be routinely shared with Jobcentre Plus staff and Atos healthcare professionals. As part of their professional development, Jobcentre Plus Decision Makers should be encouraged to attend tribunals.

Response: We will consider this recommendation, which is largely the remit of the First-tier Tribunal
Rationale: Improving the feedback between Jobcentre Plus, the First-tier Tribunal and Atos has already commenced. Consistency of decision making will be further improved through joint Regional Liaison Forums which are being established. Learning from a recent exercise whereby a joint team of Atos healthcare professionals, Decision Makers and Tribunals Service personnel reviewed cases awaiting Tribunal Hearing will also be cascaded and embedded nationally.

Descriptors and programme of work for year two

18. The review has asked Mind, Mencap and the National Autistic Society to provide recommendations on refining the mental, intellectual and cognitive descriptors. The review looks forward to receiving these recommendations in late November and will make any recommendations it sees fit to Ministers.

Response: We await a further report from Professor Harrington during late December or early January.

DA is very pleased that Mind, Mencap and the National Autistic Society will be helping improve WCA descriptors. We hope the outcome of this work is accepted and implemented by Government before people receiving Incapacity Benefits undergo WCAs. 

19. The review should examine the descriptors, in particular how they account for other fluctuating conditions and, possibly, generalised pain and provide any recommendations necessary.

Response: We accept this recommendation
Timing: Work will start immediately as part of the second independent review.
account for other fluctuating conditions and, possibly, generalised pain and provide any recommendations necessary.

Recommendations 19-25 all relate to the next review of the WCA. DA is concerned that disabled people who have been badly assessed and the 10,000 people undergoing a WCA from Spring 2011 will be very surprised that no imminent action will be undertaken despite evidenced failings to appropriately assess needs.

20. The review should examine what happens to people who are found Fit for Work, people who are placed in the Work-Related Activity Group, in the Support Group and people who do not complete their WCA.

Response: We accept this recommendation
Timing: Work will start immediately as part of the second independent review.
Work, people who are placed in the Work Related Activity Group, in the Support Group and people who do not complete their WCA.

21. In year two the review should examine what happens to individuals who are found Fit for Work but are unable to claim Jobseeker’s Allowance.

Response: We accept this recommendation
Timing: Work will start immediately as part of the second independent review.

22. In year two the review recommends that research is undertaken to understand whether the assessment could and should incorporate more “real world” or work-focused elements.

Response: We accept this recommendation
Timing: Work will start immediately as part of the second independent review.

23. In year two the review should examine the Atos computer system (LiMA) and how it can drive the right behaviours.

Response: We accept this recommendation
Timing: Work will start immediately as part of the second independent review.

24. In year two, the review should explore the use of other healthcare professionals in the Atos assessments and to check consistency of assessments by different professions.

Response: We accept this recommendation
Timing: Work will start immediately as part of the second independent review.

25. In year two the review should also monitor the implementation of those recommendations in the year one report which have been adopted by Ministers.

Response: We accept this recommendation
Timing: Work will start immediately as part of the second independent review.

3. Year one interim report

The interim report on the implementation of year one recommendations was made available on 7 June 2011 at http://tinyurl.com/37p4mh3.

The Independent review of the work capability assessment recommended that, where the claimant was referred to a Health Care Professional (HCP) for examination, that the HCP report (form ESA85) should contain a personalised summary of the assessment. This avoids the use of stock phrases from the computer system used to complete form ESA85.

The Department for Work and Pensions (DWP) have now issued guidance on this (Memo DMG 17/11:  ESA - personalised summary statement).

4. Year two review

In this, the second of five annual reviews, the Review:

  1. examines the mental, intellectual and cognitive descriptors and provide recommendations on refining them;
  2. examines the descriptors, in particular how they account for other fluctuating conditions and, possibly, generalised pain and provide any recommendations necessary;
  3. examines what happens to people who are found Fit for Work, people who are placed in the Work Related Activity Group, in the Support Group and people who do not complete their WCA;
  4. examines what happens to individuals who are found Fit for Work but are unable to claim Jobseeker’s Allowance;
  5. undertake research to understand whether the assessment could and should incorporate more “real world” or work-focused elements;
  6. examine the Atos computer system (LiMA) and how it can drive the right behaviours; explore the use of other healthcare professionals in the Atos assessments and to check consistency of assessments by different professions; and monitor the implementation of those recommendations in the year one report which have been adopted by Ministers.
  7. consider the wording of the descriptors used for claimants receiving treatment for cancer.

The second review finds that all the year one recommendations have been, or are being, implemented, some of the improvements have not reached all parts of DWP Operations, but will eventually do so.

Recommendations of the second year review

The year 2 review makes the following recommendations (all accepted by the Government - at least in principle):

  • Implementation of the Review’s recommendations should be monitored over time and on a regular basis
  • Unannounced visits to both Benefits Delivery Centres and Atos Assessment Centres should be carried out during the year three Review.
  • A ‘gold standard’ review be carried out, beginning in early 2012. Future decisions about the mental, intellectual and cognitive descriptors should be based on the findings of this review. - accepted in principle
  • DWP should consider working with relevant representative groups and their clinical advisers to:
  1. Update the handbook and guidance used by Atos healthcare professionals; and
  2. Produce practical guidance for Decision Makers.  accepted in principle
  • This ‘bottom up’ model – involving a wide range of experts as well as DWP – should also be adopted in any future changes to the WCA descriptors, where appropriate.
  • Work on the specific wording of the sensory descriptors and an additional descriptor which addresses the impact of generalised pain and/or fatigue should be considered early on in the year three Review.
  • As and when changes to the descriptors are made, DWP and other relevant experts should monitor the impact of these changes to ensure both that they are working and that they are not causing any unintended consequences.
  • DWP should consider ways of sharing outcomes of the WCA with Work Programme providers to ensure a smoother claimant journey. - accepted in principle
  • DWP should undertake regular audit of Decision Maker performance.
  • In year three, further research should be undertaken to examine in more detail what happens to people found Fit for Work and people placed in the Work Related Activity (including Work Programme outcomes) and Support Groups, and the factors influencing these outcomes.
  • Changes to LiMA, based on comments from the stakeholder seminars,  should be adopted, and that further changes to LiMA are considered as and when they are raised.
  • Atos and DWP should monitor and audit the use of free text within LiMA to ensure a consistently high standard of accurate reports.
  • If needed, Atos healthcare professionals are provided with the relevant IT training – especially typing – to enable them to use the LiMA system intelligently and ensure that the quality of the face-to-face assessment does not suffer. - accepted in principle
  • Re Healthcare professionals, given the importance of the quality of assessments (especially with Incapacity Benefit reassessment fully underway) DWP should consider tightening the target for C-grade reports. - accepted in principle
  • To improve the transparency of the face-to-face assessment, data on Atos performance and quality should be regularly published. - accepted in principle
  • DWP should continue to monitor the quality and appropriateness of DWP Operations and Atos training.
  • Where appropriate, there should be sharing of knowledge and training between the various groups involved in the WCA. - accepted in principle
  • DWP should closely monitor the recruitment, and retention, of Atos healthcare professionals in year three.
  • DWP Operations should improve internal communications to ensure that each part of the claims process and Personal Advisers have a broad understanding of the policy intent of the WCA, what a Fit for Work decision means for a claimant and the support available to them.
  • DWP Operations should continue to monitor the impact of the year one recommendations, particularly the additional ‘touch points’ with claimants, to better understand whether messages about the support available on Jobseeker’s Allowance are fully understood by claimants.
  • DWP should ensure that Universal Credit considers the risks of applying conditionality to those claimants who are currently employed. - accepted in principle
  • DWP Operations should consider seeking, and using, advice and guidance from the UK Drug Policy Commission and other relevant experts in order to improve and enhance the knowledge and capability of Decision Makers and Personal Advisers in managing these cases. - accepted in principle
  • Similar advice should be sought by Atos for their Mental Function Champions and the UK Drug Policy Commission and other relevant experts could be involved in updating the relevant sections of the Atos Guidance Manual for their healthcare professionals.

The Government year 2 response in relation to certain conditions

people undergoing treatment for cancer - Professor Harrington and the DWP accepted submissions from Macmillan Cancer Support, in conjunction with a number of other cancer charities, regarding improvements to the WCA for people who were undergoing treatment for cancer. The DWP accepts the evidence presented by Macmillan that the effects of oral chemotherapy can be as debilitating as other types of chemotherapy and that certain types of radiotherapy and in particular of combined chemo-irradiation can be equally debilitating.

In its publication Work Capability Assessment: Government response to an informal consultation on accounting for the effects of cancer treatments the Government has issued revised proposals which will mean that more people with cancer will be placed in the support group. The revised proposals expand the categories of cancer treatments under which a claimant may be treated as having LCWRA, to now include individuals who are;

  • Awaiting, receiving or recovering from treatment by way of chemotherapy irrespective of route; or
  • Awaiting, receiving or recovering from radiotherapy.

the mental function descriptors - In September 2010, Professor Harrington tasked Mind, Mencap and the National Autistic Society to suggest refinements to the mental function descriptors. The DWP believes that the proposals developed by the charities lacked evidence to support making changes to the descriptors though Professor Harrington recognised the need for further work to be done to develop a detailed evidence base about the functioning of the current descriptors and whether there are improvements that could be made.

The DWP is currently engaging with Mind, Mencap and National Autistic Society to consider whether there are changes that could be made to the ESA50 questionnaire. In particular, DWP wish to understand whether it is possible to incorporate elements of the recommendations around frequency, severity and duration into the questionnaire to improve the collection of information from individuals with mental function conditions.

fluctuating conditions - Professor Harrington set up a group to assess whether there were specific improvements to the descriptors for individuals with fluctuating conditions. This group included representation from a number of disability groups, including Arthritis Care, Crohn’s and Colitis UK, Forward ME, the MS Society, the National AIDS Trust and Parkinson’s UK. Professor Harrington has recently received the final report from the group and has submitted it to the Department. The DWP will consider his recommendations and respond in due course.

5. Year 3 review

This third review asked questions which were deliberately focused on people who have been through the WCA process although advocacy groups and others could also contribute to the call for evidence.

In year three Professor Harrington was particularly interested in views and evidence about the implementation of his recommendations and any changes to:

  • communications
  • face-to-face assessment
  • decision making

The closing date for responses was 7 September 2012.

Disability Rights UK response

As well as answering the specific Harrington questions, of our almost 800 respondents also reported:

  • 89% say the WCA is unfit for purpose;
  • 83% say the system doesn’t help disabled people find work; and
  • 93% say DWP must demonstrate how the WCA is helping people move into employment.

The case for improving the WCA is stronger by the day – with far too much money wasted on an unfit test which could help disabled people get and keep work.

You can view our full response in the More information section.

Recommendations of the third year review

In November 2012 Professor Harrington published his third independent review of the Work Capability Assessment (WCA). On the same day the Government responded to the recommendations within the review.

The first two Reviews concluded that the WCA is the right concept but needs improvement to the working of the system. All the recommendations of these reviews have been accepted by the Government though not all have been fully acted upon yet. These include:

  • Written communications to the claimant are clearer, less threatening, and more fully explain the process.
  • The ESA50 questionnaire includes a new section for the claimant to express the issues they face with a personalised justification.
  • Atos has produced a customer charter setting out clearly what claimants can expect.
  • Atos has introduced Mental Function Champions as a specialist resource to spread best practice for their Healthcare Professionals.
  • Changes to the WCA descriptors widened the criteria for support in relation to people’s mental function.
  • Improved training has been introduced for Atos Healthcare Professionals and DWP Decision Makers to empower them to take the best possible considered decisions.
  • A help line is in place to help Decision Makers contact Atos healthcare professionals where they need advice.
  • A Quality Assurance Framework has been developed to assess Decision Makers consistency and accuracy.
  • Decision makers attempt contact with claimants by telephone before a final decision is taken to explain the process and offer the opportunity to provide further evidence to the Decision Maker before they make their final decision.
  • Decision Makers provide claimants with a ‘Decision Maker Reasoning’, outlining their reasoning to explain how they have come to their conclusion.

The year three Review has examines the scale of change that has occurred, driven forward outstanding areas of work from previous Reviews and has proposed additional recommendations to further the scope of change.

Recommendations and the Government response

Implementation of the year one and two recommendations

  • Decision Makers should actively consider the need to seek further documentary evidence in every claimant’s case. The final decision must be justified if this is not sought. Response: Provisionally accept, subject to the caveat that we must first work to ensure it can be implemented in a cost effective fashion before taking a final decision
  • In order to build on the progress already made DWP Operations need to find an appropriate balance between better quality decisions that are carefully considered and ‘right first time’ and the achievement of appropriate benchmarks at local level, otherwise there is a real risk of derailing the positive progress made to date. Response: Accept. The Department, through the Benefits Directorate, is currently reviewing benchmarks and will continue with Quality Assurance Framework calibration exercises to improve decision making standards.
  • DWP should continue to work with the First-tier Tribunal Service, encouraging them to, where appropriate, ensure robust and helpful feedback about reasons for upheld appeals. Response: This focuses on the work already underway with the First Tier Tribunal Service and the use of the ‘drop down menu’ This work is ongoing and the Department therefore accepts this recommendation.
  • DWP must take the initiative and highlight the improvements that have been made where they exist, as well as being open about where problems remain and their plans to address these. Response: We accept this recommendation.

Training

  • The year four and five Reviews should further explore the quality of the outcomes rather than simply on the quantity of the training offered. Response: A final decision on what should be covered in the fourth year review will be at the discretion of the new independent reviewer. However, we support the proposal that this could be a fruitful area to be considered in next year’s review.

Complex problems and chaotic lifestyles

  • DWP Operations and Atos Healthcare should take further steps to engage effectively and meaningfully with the UK Drug Policy Commission and other related groups concerned with the needs and difficulties of problem drug users to improve the WCA processes for them. Response: Accept. We will continue to engage such groups as we continue to update and refine our guidance and training materials.

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