The ME Association welcomes the publication of the House of Commons Work and Pensions Committee report on the Government’s proposed disability benefit reforms, tabled under the ‘Pathways to Work' agenda.
The report, published 29th July 2025 (HC 837), scrutinises key legislative changes to Universal Credit and Personal Independence Payment (PIP) and issues a number of recommendations that directly reflect long-standing concerns raised by the ME Association on behalf of people with ME/CFS or Long Covid.
The ME Association submitted a detailed response as part of the consultation for Pathways To Work and we are pleased that our evidence has been cited multiple times in this Select Committee report. It is clear that the Select Committee has seriously considered the impact of these proposals on people with ME/CFS or Long Covid, as well as the more general nature of how invisible, fluctuating* or energy limiting conditions may affect people under these proposals.
*N.B. Where the use of the word ‘fluctuating' is used, this is to align with DWP terminology.
Key Committee Conclusions
The Committee issues a clear warning that scrapping the Work Capability Assessment (WCA) and linking Universal Credit health entitlement solely to PIP will risk excluding many people with significant functional limitations who are nonetheless unable to meet the narrow criteria for PIP daily living. This echoes one of the MEA’s core objections, outlined in both our previous Select Committee and Green Paper submissions.
We are concerned that abolishing the WCA and moving to a single benefit assessment could cause hardship for people who currently qualify for the health-related element of UC but who would not qualify for PIP.
House of Commons Work and Pensions Committee report
The Committee also criticises the Government’s failure to model the impact of this reform accurately:
It is unacceptable that the Department has not published a full impact assessment of how many people will lose their additional UC entitlement as a result of the proposed changes.
House of Commons Work and Pensions Committee report
Safeguarding and Fluctuating Conditions
Importantly, the report raises serious concerns about safeguarding. The Committee warns that the new system could leave vulnerable people without adequate support if they fall through gaps in the redesigned eligibility criteria. It highlights the importance of recognising fluctuating*, energy-limiting conditions and the challenges they pose to functional assessments.
There is a risk that people with fluctuating conditions or less visible impairments may be excluded from support under the new system.
House of Commons Work and Pensions Committee report
For example, someone living with ME/CFS or Long Covid may experience debilitating fatigue, pain, and cognitive dysfunction that make work impossible – but they may not meet the daily living thresholds in PIP, especially under the current functional scoring system.
Under the proposed reforms, this individual could lose access to the Universal Credit health element altogether, despite having no realistic ability to work and a clear risk of harm if pressured to do so. This is exactly the type of gap in protection the Work Capability Assessment currently helps to mitigate, particularly through safeguarding mechanisms like Regulations 29 and 35.
It is important to recognise that multi-systemic safeguarding failures affecting people with ME/CFS are not new. Recent high-profile cases in the media have highlighted the tragic consequences of systemic disbelief and under-recognition. These failures underscore a wider cultural problem across public services – including within benefits assessments – where fluctuating*, poorly understood conditions are routinely dismissed or misunderstood. Without robust safeguards, the proposed reforms risk compounding these dangers by removing the limited protections that currently exist.
Committee Recommendations
The Committee calls on the Government to:
- Conduct a full impact assessment before further progression of the reforms.
- Retain a route to support for those not qualifying under PIP but unable to work.
- Co-produce future eligibility frameworks with disabled people and expert stakeholders.
- Ensure proper safeguards for those at risk of harm if support is withdrawn.
ME Association Position
The ME Association is directly cited multiple times in this report:
- Para 61 highlights concerns about the four-point rule and its impact on fluctuating conditions: “There was particular concern about the impact on those with fluctuating conditions, including ME […] The ME Association said the approach failed to reflect the cumulative impact of complex conditions and risked disadvantaging claimants with fluctuating or invisible impairments.”
- Para 84 references the MEA’s criticism of the inadequate impact assessment: “The ME Association said [the absence of a proper impact assessment] was hindering stakeholders’ and Parliament’s ability to scrutinise the proposals.”
- The MEA is also listed formally in the appendix as a contributing organisation (PTW0029)
The ME Association has consistently raised these issues throughout 2025. In our submission to the Green Paper consultation, our briefing to MPs, and our published blogs, we have:
- Warned that replacing the WCA with a sole reliance on PIP daily living criteria would exclude many people with ME/CFS or Long Covid.
- Challenged the inadequacy of the impact modelling and lack of safeguarding plans.
- Urged DWP to retain mechanisms such as Regulation 29 and 35, which currently allow those at risk to be protected.
- Called for trauma-informed, co-produced reform that recognises the fluctuating*, invisible, and disabling nature of ME/CFS and Long Covid.
As we noted in our blog published 14 July 2025, ‘Universal Credit and PIP Bill: what happened at the Third Reading‘, the withdrawal of Clause 5, removing proposed changes to PIP eligibility, was a critical step – but without a robust alternative, the same risks remain.
What Next?
The ME Association will continue to push for meaningful engagement in any future co-production processes and to ensure that our community’s needs are represented at every stage.
Although the Bill is now progressing through its final stages in the House of Lords as a money bill – meaning that amendments cannot be made – we urge Peers to use their voices to press the Government on the importance of safeguarding and inclusion. It is vital that the principles outlined by the Committee are not lost as secondary legislation is developed.
Ella Smith
Welfare Rights Consultant,
The ME Association
Further Information
- The ME Association’s Position Statement on the Proposed Welfare Reforms | June 18, 2025
- The ME Association: Welfare reform: The Universal Credit Bill – why it matters to people with ME/CFS and Long Covid | July 4, 2025
- The ME Association: Universal Credit and PIP Bill: what happened at the Third Reading | July 10, 2025
- Welfare reforms: The ME Association strongly opposes government press release | June 20, 2025
- The ME Association: Fighting for Fairness: We Need Your Voice to Challenge Benefit Reforms | June 19, 2025