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Pathways to Work Green Paper: what’s changing and how it impacts students?

In March 2025, the Government unveiled plans to reform the welfare system in the Pathways to Work: Reforming Benefits and Support to Get Britain Working Green Paper.

No immediate changes

While there are no immediate changes, the proposed reforms are expected to result in financial losses for many. The changes are scheduled to begin rolling out from April 2026.

 

Summary of Proposed Changes in the Green Paper 

Scrapping the Work Capability Assessment (WCA)

The Government has announced that it will scrap the Work Capability Assessment (WCA) in 2028/29. From this point, they will use the PIP assessment for all health and disability benefits in England and Wales to determine extra financial support for health conditions under Universal Credit (UC).

The additional health element in UC will be based solely on whether someone receives the Daily Living Award in PIP, not their ability to work.

This is not being consulted on.

Changes to PIP

The new rules will require individuals to score at least 4 points in one daily living activity to qualify for the PIP daily living component. This change will apply to new and existing claimants at their next award review. The intention is to implement these changes in 2026/27, possibly as early as November 2026. The mobility component will remain unaffected.

The consultation is exploring whether individuals who lose PIP eligibility need support and what form that support should take, including offering a review of their health and care needs.

Changes to Universal Credit (UC)

The UC standard allowance will increase by £7pw from £91 in 2024/25 to £98pw by 2026/27. The Government will then freeze the health element of UC at £97pw until 2029/30. For new claimants, it will be reduced to £50pw from April 2026 and remain frozen until 2029/30.

 This is not being consulted on.

Exemptions and Premiums

People with “the most severe, life-long health conditions, who have no prospect of improvement and will never be able to work” will be exempt from future reassessments. The Government is considering offering these individuals an “additional premium”, but the list of eligible conditions remains undefined.

People assessed as limited capability for work and work-related activity (LCWRA) before April 2026 will continue to receive the UC health element, provided they meet the criteria following reassessment.

This is not being consulted on.

Trying Work

The Government plans to introduce legislation stating that trying work will not lead to a reassessment or potential loss of benefits. 

This legal guarantee will apply to people receiving Universal Credit (UC), Personal Independence Payment (PIP) in England and Wales, or New Style ESA. The Government plans to bring this legislation forward as soon as possible and apply it to the current and reformed systems.

This is not being consulted on.

Changes to Age Rules

The Government is consulting on raising the age of transition from Disability Living Allowance for children (DLAc) to PIP from 16 to 18. These changes mean some claimants may benefit financially but others will likely face financial losses. 

They are also considering delaying access to the UC health element until age 22, meaning delays in when young disabled people can receive additional support.

The Government are consulting on this.

New Unemployment Insurance Benefit

Replacing contribution based Jobseeker’s Allowance (JSA) and Employment and Support Allowance (ESA) with a single entitlement, paid at the current ESA rate (£138 per week) and time-limited. This would end indefinite entitlement to contributory ESA for new claimants assessed as having limited capability for work-related activity. After the time-limited period, unemployed individuals could claim Universal Credit (UC) based on their circumstances.

The Government are consulting on this. Indicative implementation date 2028/29.

Pathways to Work

The Pathways to Work initiative is a guarantee to a personalised employment, health and skills support for anyone on out-of-work benefits with a work-limiting health condition or disability who wants it. It aims to combine existing support programs like WorkWell, Individual Placement and Support, Connect to Work, and Get Britain Working along with the new national jobs and careers service.

While this is mainly an England only policy, the consultation and proposals are also relevant to Scotland and Wales in areas where the UK Government retains responsibility, such as certain aspects of employment support. In Northern Ireland, social security and employment support are devolved matters, meaning the Department for Communities oversees these areas.

The consultation covers proposals for a new Support Conversation, setting a baseline for engagement expectations, and reforms to Access to Work and workplace adjustments.

 

What is NASMA’s policy position?

It’s clear that the Green Paper has not considered students who claim Personal Independent Payment (PIP) & Universal Credit (UC) in this consultation.

Impact of PIP changes on full-time students

Currently, full-time students are eligible for UC if they have been assessed as having a Limited Capability for Work before they start their course  and  they are in receipt of PIP. For full-time students in receipt of PIP it can help them significantly manage the additional challenges and costs associated with a long-term health condition or disability. The support that PIP itself can offer ensures they can cover the costs of extra expenses such as mobility aids, special dietary needs or personal care/support services, not covered by the student funding system.

Allowing students who are in receipt of PIP access to UC ensures that they can also cover their additional living costs because of their disability. Many students on PIP and UC do not live in “standard” student accommodation options and instead  live  in self-contained accommodation which are usually more expensive than shared houses or student flats. Access to UC is often essential to cover these costs as the current student funding system is inadequate.

Currently, full-time students are only eligible to apply for UC, if they are in receipt of PIP AND they have been assessed as having limited capability for work. If the government scraps the WCA assessment, then no new full-time students will meet this criteria and would all lose access to UC. The criteria will have to be changed so that full-time students only need to be in receipt of PIP to be eligible to apply for UC, as the WCA element will no longer exist

Interaction of benefits and the Student Finance system

Full-time and part-time students in receipt of PIP are eligible for the Special Support Element of their maintenance funding.  This means that, dependent on household income, they receive a slightly higher amount of maintenance loan, acknowledging that these students may have higher maintenance costs and higher study costs. The SSE element means that their maintenance funding has less   impact on their Universal Credit entitlement.. NASMA is concerned that the current proposals of reducing PIP eligibility  will have a substantial impact on full-time and part-time students. If they lose their entitlement to PIP, they will no longer be eligible for the Special Support Element of their maintenance funding.

Financial Impact of PIP changes, an example based on 2025/26 figures:

A full-time student, living in Leeds, not living in the parental home, funded through SFE on a standard length undergraduate non specialism course, not in their final year, who is eligible for PIP, but loses their eligibility due to the new assessment, would lose the following income:

PIP at £73.90 a week loss of £3842.80
PIP gives access to SSE element of funding loss of £1,475
PIP and LCW gives access to UC based on only being eligible during the summer due to maintenance funding being counted in term time loss of £1,888
Total loss for the year £7,205

 

Students will be ineligible for mitigating initiatives

Students are not seeking work, thus unlikely to be eligible for the mitigating incentives offered through the Pathways to Work while they study.

Disabled Student Allowance (DSA) can’t replace PIP

Students can apply for the Disabled Student Allowance (DSA) for support with the cost of study and having a disability, such as a non-medical helper to assist with study, additional study related equipment and travel costs to study. PIP was designed to help individuals with the extra costs associated with having a long-term physical or mental health condition or disability by providing a daily living component and a mobility component. PIP and DSA are two different funding packages, DSA cannot replace PIP for a student as it pays for specific study related costs rather than general living and mobility costs of having a disability.

Gap in support for 18-21 year olds

NASMA is concerned that there will be a significant gap in support for students aged 18-21 if the age rules change for UC health element. This age group is particularly vulnerable, especially those with mental health issues, and the current proposals do not address their needs adequately.

Summary of policy position

NASMA are disappointed that there is no mention of students and the impact of these reforms on students in the Green Paper. The current arrangements were designed to allow those who are on disability benefits to transition to study at Higher Education level and not lose all their benefits. The Green Paper proposes to reduce those entitled to PIP. Losing PIP would result in a significant loss of funding for students, impacting more than just the PIP payments. The number of disabled students is increasing year on year. It’s crucial that the reforms do not hinder the progress made in widening access to education for disabled students.

 

What is NASMA doing?

We are responding to the consultation by e-mail expressing our policy position above and our concerns.

What can you do?

We are encouraging NASMA members to also respond to the consultation, either as individual NASMA members or on behalf of your institution (with permission). The consultation is open until 11:59pm on 30 June 2025.

Respond online here

Or by e-mail: Consultation.pathwaystowork@dwp.gov.uk