We have submitted a response to the Welsh Government consultation Framework for Regional Investments in Wales, on behalf of the  Engage to Change employment project (which includes Learning Disability Wales, Agoriad Cyf, All Wales People First, ELITE Supported Employment Agency and the National Centre for Mental Health at Cardiff University, as partners).

What is the Framework for Regional Investments?

The Framework for Regional Investments is a new Welsh Government policy that aims to:

  • support growth and inclusiveness across Wales
  • focus on delivering outcomes
  • decentralise funding and decision-making
  • integrate with other policies and wider opportunities for investment.

Our Response

Engage to Change is a pan-Wales employment project for young people with a learning disability and/or autism aged 16-25 who are not in education, employment or training (NEET) or at risk of becoming NEET. Our vision is of a world in which people with a learning disability and/or autism are able to experience improved wellbeing outcomes through the increased independence, financial status, social capital and fulfilment that paid work offers.

We welcome the opportunity to submit evidence to Welsh Government on this proposed policy. The overall policy aims are positive ones and we are happy to see Welsh Government aiming to entrench equality more deeply into its policies. We will be providing evidence to Questions 2 and 5 of the consultation.

Q2. Do you support our proposals for some investments to be led by the community in which the activity takes place?

We welcome the proposal for investments to be led by the community in which activity takes place. It is important that local communities and organisations who work within those communities are given control over strategic decisions throughout the process of planning and delivering services. It is important too that existing services and projects are recognised and supported where they are available, and their expertise and experience is fully utilised. Significant resources are wasted through funding models that force service providers to continuously reapply for what should be a statutory service, such as supported employment.

In the past, Welsh organisations have often struggled to get PRIME contracts from the DWP because organisations were too small to compete with bigger providers from England who lack local knowledge and contacts. Furthermore, given the high management and consultancy fees the large providers charge, this means that significant money was siphoned out of Wales. In areas such as supported employment, it makes sense to prioritise local service providers and support the local community, strengthening the community, both through the service providers and the jobs created within the service provider.

Q5. How best can we integrate the horizontal themes of equality, sustainable development, gender mainstreaming and the Welsh Language into investments delivered at national, regional and local levels?

We welcome the plan to integrate the horizontal themes into the delivery of investments. As a project supporting people with a learning disability and/or autism into work, we have expertise in the challenges and barriers disabled people face in getting and retaining work. We have had significant success with our own approach of job coaching, which supports people with a learning disability and/or autism into work using an individualised model that offers training and support on a one-on-one basis[1]. This means ring fencing money for supported employment, supported internships and inclusive apprenticeship programs that will make workplaces more accessible.

The situation for people with a learning disability and/or autism will be even more precarious in the wake of the Coronavirus pandemic. The nature of our economy, particularly in North and West Wales, is particularly susceptible to the effect of Covid 19 with tourism and hospitality being the bedrocks of it. As most of this trade has a seasonal cycle, changes to how these sectors can operate may need to be considered.

With a huge increase in unemployment looming there is going to be a real challenge in maintaining the rights of disabled and disadvantaged people to be part of the economic recovery. There is, however, scope for WG to provide ring-fenced funding to support the aim of ensuring disabled people are included in the economic picture. There are 4 specific areas that we believe should be focused on as a starting point:

  • Ring fencing funding for a National Job Coaching Scheme to provide the support people and employers need to get people with a learning disability and/or autism into paid employment.
  • Developing a Supported Internship offer that enhances college and school transition to employment for people with a learning disability and/or autism, and that draws on a National Job Coaching Scheme
  • Ensuring that any Prime contractors bidding for contracts such as Job Support Wales are required to satisfy any specific specialist disability requirements within DWP /JC+ contracts through specialist indigenous providers based in Wales.
  • The proposed Job Support Wales scheme is expanded and an element is used to contribute to the ring-fenced National Job Coaching Scheme to ensure people with a learning disability and/or autism are not left behind in the competition for new jobs post-Covid-19.


We must also emphasis that structural inequality cannot be fixed solely through individual initiatives and that all the different themes, as well as the economic inequality mentioned elsewhere, are intimately linked. If Welsh Government is to effectively tackle these inequalities and injustices, then measures to combat them must be integrated into planning from the outset. For people with a learning disability and/or autism, this means that their voices must matter, not just as a form of evaluation but also in the process of planning. We note with disappointment that this consultation itself was not translated into an easy read accessible format. If Welsh Government is serious about creating a society that works for all, we would suggest that they make the process with which they aim to achieve this society accessible to all.

We also note that in our own project we have really struggled to place people with a learning disability and/or autism into jobs or paid work placements within the public sector. Making sure that the workplaces and jobs are suitable for disabled people often requires changes to rules and flexibility from other staff members. We have found that the public sector is significantly less likely to make those changes. If Welsh Government is serious about closing the disability employment and pay gaps it will have to make sure that its own practices reflect that. Welsh Government cannot reasonably expect to further equality in society if it cannot incorporate equality into its own practices.

Finally, we are also concerned about some of the phrasing in the document. On page 23 of the consultation document you write that

“Our aim is to maximise the number of people in good quality work where they are secure and healthy, ensuring this is shared fairly across geographies and demographics, particularly amongst under-represented groups. The reason for this is that evidence, for example by the OECD19, shows that inequality has a negative impact on economic growth.”

While it might be true that there is a correlation between social equality and economic growth, the main reason that people deserve good quality work is that it is a social good in itself. Creating a society in which everyone is able to live a meaningful and secure life should be the primary aim of legislation here, not economic growth.

Thank you for the opportunity to contribute to this consultation. For further information please contact Grace at Learning Disability Wales: Grace.Krause@ldw.org.uk.


[1] More information on what we have learned about effective employment through our project can be found in our project evaluation on our website.