Reasonable Adjustments
Advanced Claimant Protection, Legal Rights, Accessibility and Accountability Handbook
Everyone has the right to access public services fairly and without unnecessary barriers.
The Department for Work and Pensions (DWP) has legal duties to ensure that disabled people and people with health conditions are not placed at a substantial disadvantage when accessing benefits, employment support, assessments, reviews, Jobcentre services, appeals, or other DWP-administered services.
Reasonable adjustments are one of the key legal protections available to ensure equal access.
These protections apply across many DWP services, including:
• Universal Credit (UC)
• Personal Independence Payment (PIP)
• Employment and Support Allowance (ESA)
• Attendance Allowance
• Carer's Allowance
• Pension Credit
• State Pension services
• Access to Work
• Jobcentre Plus services
• Mandatory Reconsiderations
• Tribunal and appeal processes
What Are Reasonable Adjustments?
Reasonable adjustments are changes, accommodations, or support measures intended to remove barriers that may disadvantage disabled people or people with long-term health conditions.
The purpose is to help ensure fair and equal access to services.
Reasonable adjustments are not special treatment.
They are intended to ensure equality of opportunity and accessibility.
Legal Framework
Equality Act 2010
The Equality Act 2010 provides one of the strongest legal protections relating to reasonable adjustments.
Official Legislation:
https://www.legislation.gov.uk/ukpga/2010/15/contents
Official Guidance:
https://www.gov.uk/guidance/equality-act-2010-guidance
Duty to Make Reasonable Adjustments
Under the Equality Act 2010, service providers and public authorities may be required to take reasonable steps to avoid substantial disadvantage experienced by disabled people.
This duty is anticipatory for public services, meaning organisations should think ahead about accessibility rather than waiting until barriers arise.
Public Sector Equality Duty (PSED)
Section 149 of the Equality Act 2010 requires the DWP to:
• Eliminate discrimination
• Advance equality of opportunity
• Foster good relations
• Consider disability-related disadvantage
• Improve accessibility
Official Guidance:
Human Rights Act 1998
Public authorities should make decisions and provide services in ways that are fair, proportionate and respectful of individual dignity.
Official Legislation:
https://www.legislation.gov.uk/ukpga/1998/42/contents
Who May Need Reasonable Adjustments?
Reasonable adjustments may be relevant for people with:
• Physical disabilities
• Sensory impairments
• Learning disabilities
• Cognitive impairments
• Autism
• ADHD
• Dyslexia
• Dyspraxia
• Mental health conditions
• Long-term illnesses
• Neurological conditions
• Chronic pain conditions
• Fatigue-related conditions
• Communication difficulties
• Temporary disabilities in some circumstances
The focus is generally on the barriers experienced rather than the label attached to a condition.
Examples of Reasonable Adjustments
The most appropriate adjustment depends on individual circumstances.
Examples may include:
Alternative Communication Formats
• Large print
• Braille
• Audio formats
• Easy Read documents
• Electronic formats
• Accessible digital communication
Additional Appointment Support
• Support workers
• Advocates
• Interpreters
• Family members or carers where appropriate
• Communication assistance
Telephone Appointments
Where appropriate, appointments may be conducted by telephone rather than face-to-face.
Video Appointments
Remote appointments may be suitable in some situations.
Communication Support Services
Examples include:
• British Sign Language (BSL) interpreters
• Lipspeakers
• Communication support workers
• Language support where available
Longer Appointment Times
Additional time may help people:
• Process information
• Explain circumstances
• Communicate effectively
• Manage anxiety or distress
Accessibility Support
Examples include:
• Step-free access
• Accessible interview rooms
• Quiet waiting areas
• Sensory adjustments
• Home visits where appropriate
• Flexible scheduling
Jobcentre and Assessment Adjustments
Reasonable adjustments may be requested during:
• Jobcentre appointments
• Work coach meetings
• Work capability assessments
• PIP assessments
• Universal Credit interviews
• Mandatory Reconsiderations
• DWP reviews
• Complaints procedures
• Appeals and tribunal processes
People Should Not Be Disadvantaged
A core principle of equality law is that people should not be disadvantaged because of:
• Disability
• Illness
• Health conditions
• Communication barriers
• Accessibility needs
• Cognitive impairments
• Mental health difficulties
Public services should take reasonable steps to reduce barriers wherever possible.
Accessibility Rights
The DWP should make services accessible.
Official Information:
https://www.gov.uk/support-when-you-contact-dwp
Support may include:
✓ Alternative formats
✓ Accessible communication
✓ Assistance completing forms
✓ Additional support during assessments
✓ Accessible appointment arrangements
✓ Communication support
Evidence and Adjustment Requests
You may be asked to explain why an adjustment is needed.
Evidence might include:
• Medical evidence
• Professional reports
• Educational support plans
• Occupational therapy reports
• Support worker statements
• Existing adjustment arrangements
However, adjustment requests should generally be considered reasonably and proportionately.
Safeguarding Considerations
Additional support may be appropriate where someone:
• Has dementia
• Experiences severe mental distress
• Has communication difficulties
• Has cognitive impairments
• Is vulnerable to exploitation
• Requires assistance understanding processes
Safeguarding should be considered alongside accessibility needs.
Decision-Making Standards
The DWP should:
• Consider adjustment requests fairly
• Consider individual circumstances
• Follow equality legislation
• Follow policy guidance
• Avoid unnecessary barriers
• Provide reasons for decisions
• Consider safeguarding issues
Administrative Law Principles
The DWP should act consistently with:
Lawfulness
Following legislation correctly.
Rationality
Making evidence-based decisions.
Procedural Fairness
Allowing meaningful participation.
Transparency
Providing understandable explanations.
Consistency
Applying policies fairly.
If an Adjustment Is Refused
You may:
• Ask for reasons
• Request reconsideration
• Provide further information
• Make a complaint
• Seek independent advice
• Raise equality concerns where appropriate
Complaints About Accessibility
Complaints may relate to:
• Failure to provide adjustments
• Communication barriers
• Accessibility barriers
• Failure to consider disability-related needs
• Poor service delivery
Official Complaints Procedure:
https://www.gov.uk/government/organisations/department-for-work-pensions/about/complaints-procedure
Equality and Discrimination Advice
Equality Advisory and Support Service (EASS)
https://www.equalityadvisoryservice.com
Equality and Human Rights Commission (EHRC)
https://www.equalityhumanrights.com
Independent Advice and Advocacy
Citizens Advice
https://www.citizensadvice.org.uk
Disability Rights UK
https://www.disabilityrightsuk.org
Scope
Age UK
Carers UK
Law Centres Network
Practical Protection Checklist
✓ Tell the DWP about accessibility needs as early as possible.
✓ Request adjustments in writing where possible.
✓ Keep copies of correspondence.
✓ Explain barriers clearly.
✓ Keep records of conversations and appointments.
✓ Obtain supporting evidence if available.
✓ Ask for reasons if requests are refused.
✓ Seek independent advice if problems arise.
✓ Make complaints where appropriate.
✓ Escalate unresolved issues where necessary.
Advanced Accountability Framework
The DWP is accountable through:
• Equality Act 2010 duties
• Public Sector Equality Duty
• Human Rights Act 1998
• Social Security legislation
• Parliamentary scrutiny
• Independent Case Examiner investigations
• Ombudsman investigations
• Judicial review principles
• Administrative law obligations
Claimants are entitled to expect services that are:
✓ Accessible
✓ Fair
✓ Inclusive
✓ Lawful
✓ Non-discriminatory
✓ Evidence-based
✓ Transparent
✓ Respectful
Claimant Accessibility Charter
Every person accessing DWP services should be able to expect:
✓ Equal access to services
✓ Respect and dignity
✓ Accessible communication
✓ Reasonable adjustments where required
✓ Protection from discrimination
✓ Fair consideration of individual needs
✓ Safeguarding support where appropriate
✓ Clear explanations
✓ Access to complaints procedures
✓ Independent challenge rights
Key Message
Reasonable adjustments are a fundamental part of ensuring equality and accessibility within DWP services. The DWP is legally required to consider disability-related barriers and take reasonable steps to help ensure that disabled people and people with health conditions are not placed at a substantial disadvantage. These protections arise from equality law, human rights principles, public sector duties and administrative law standards. Every claimant has the right to accessible communication, fair treatment, respect, dignity, reasonable adjustments, and meaningful access to benefits, employment support and decision-making processes regardless of sex, gender identity, disability, race, religion, age, sexual orientation or background.