The “cumulative impact” problem in social welfare:Some legal, policy and theoretical solutions

Notwithstanding its central place in social security policy-making and in the experiences of those on the receiving end of welfare reforms, cumulative impact is an under interrogated and theorised problem in social welfare scholarship. This paper seeks to address this in two ways. First, it draws on the lessons of the comparatively well-developed literature on cumulative impact in environmental studies to: (i) identify different dimensions of cumulative impact and (ii) best practices in undertaking cumulative impact assessments. Second, it argues that having regard to cumulative impact is not just good policy-making, but is also a legal obligation. To discharge the “Public Sector Equality Duty” under s.149 Equality Act 2010, a public authority needs to have due regard to clear cumulative impacts between measures. In the context of social security policy-making, a failure to undertake enquiries to establish cumulative impacts between polices is likely to breach the PSED. Drawing on examples from the UK Government’s Welfare Reform Act 2012 and the Welfare Reform and Work Act 2016 throughout, the paper makes the case for both the importance of addressing cumulative impact in policymaking, and the need for greater interrogation by social welfare scholarship.