Disability Wales has submitted its response to the Timms Review of Personal Independence Payment (PIP), drawing on evidence gathered from disabled people across Wales through surveys, focus groups and ongoing engagement with our members and partner organisations.
Our evidence demonstrates that PIP is not an optional or supplementary benefit, but a foundational component of independent living for many disabled people.
It enables people to meet the additional costs associated with disability, maintain their health and wellbeing, access support, and participate in society on an equal basis.
Survey respondents and focus group participants consistently described PIP as a “lifeline” rather than a benefit in the conventional sense.
The evidence also highlights significant concerns about previous proposals to tighten eligibility criteria, barriers within the assessment process, the cost of obtaining supporting medical evidence, and the impact that benefit insecurity can have on physical health, mental wellbeing and employment.
Respondents warned that reducing access to PIP would not reduce the additional costs associated with disability, but would instead increase poverty, worsen health outcomes, undermine independence, and place additional pressure on already stretched public services.
Our submission also raises concerns about the accessibility and inclusivity of consultation and engagement processes to date, as well as the absence of Wales-specific impact assessments relating to proposed reforms.
We believe that any future reforms must be developed with disabled people from the outset and be grounded in the social model of disability, dignity, inclusion and fairness.
Our Recommendations
Based on the evidence gathered, we are calling on the Timms Review to take the following actions:
1. Do not proceed or replan proposals with eligibility tightening measures that reduce access to PIP
Proposals regarding any changes should not be implemented, without planning from the beginning with disabled people. A new system would need to reflect the cumulative and complex nature of disability.
2. Recognise and protect PIP as a non-means-tested, cost-of-disability benefit
The Review should reaffirm that PIP is designed to meet the additional costs associated with disability and should not be reframed as an incentive-based or work-conditional benefit.
3. Reform the assessment process to make it fair, proportionate, and evidence-based
This should include:
- Reducing unnecessary bureaucracy and repetition within applications and reviews
- Ensuring that claimant experience is central to system design
- Moving towards a more holistic, person-centred assessment model
4. Remove financial barriers to accessing evidence
Claimants should not be required to pay for GP letters or medical documentation to access support. The Review should ensure that evidence can be obtained and shared without cost to the individual.
5. Give greater weight to clinical and practitioner evidence
Decision-making processes must properly reflect input from healthcare professionals and other practitioners, reducing reliance on narrow, standardised assessment criteria that fail to capture real-world need.
6. Reduce reassessment requirements for long-term and degenerative conditions
For individuals with conditions that are unlikely to improve, reassessment cycles should be significantly extended or removed to reduce distress, instability, and administrative burden.
7. Embed safeguarding and risk assessment into all aspects of PIP policy
Given the clear evidence of links between benefit insecurity and deteriorating mental health, including suicidal ideation, safeguarding considerations must be central to both policy design and delivery.
8. Explore the devolution of disability benefits to Wales
The UK Government should work in partnership with the Welsh Government, Disabled People’s Organisations (DPOs), and disabled people to explore the devolution of disability benefits, including PIP, to Wales. A devolved system would enable policies to be designed in alignment with Welsh legislation, including the Well-being of Future Generations (Wales) Act 2015, and ensure that support reflects the specific social, economic, and geographical realities of Wales. Any future system must be co-produced with disabled people and grounded in the social model of disability, prioritising dignity, inclusion, and fairness.
You can read our full submission by downloading the document below.





