A/HRC/17/34/Add.2 to receive benefits.35 The habitual residency status requirement represents a considerable obstacle for members of vulnerable groups, particularly people experiencing homelessness, Travellers, asylum-seekers and refugees, migrant workers and returning Irish migrants, to access services to which they are entitled. Any unfair exclusion from the protection of social transfers is unacceptable from a human rights perspective. 46. The independent expert notes the Government’s decision to amalgamate employment and training services and social protection measures under an all-inclusive National Employment and Entitlements Service within the Department of Social Protection, replacing the Irish National Training and Employment Authority (FÁS).36 It is vital that the Government ensures that this Service is designed and implemented from a human rights perspective, such that it improves beneficiaries’ access to assistance and does not create further administrative barriers to claiming their entitlements. The independent expert recommends that the Government ensure widespread consultation with beneficiaries when establishing the Service in order for it to adequately respond to their needs. 47. The independent expert is concerned about the lack of standard implementation of eligibility criteria in the social protection system, which results in a large number of appeals to the Social Welfare Appeals Office being ultimately decided in favour of the appellant.37 The transparency of the social protection system should be enhanced so that beneficiaries have access to clear information about the criteria and process by which decisions are made. The decisions of the Social Welfare Appeals Office should be published in a form which allows for broad dissemination and understanding among existing and potential beneficiaries. Efficiency in making and publishing decisions should be a priority, thus the Government’s commitment to clearing the backlog of appeals pending before the Office is a welcome move. B. Undermining public service delivery 48. While reforming the public service to ensure that resources are utilized effectively and services delivered efficiently is an essential measure, particularly in times of crisis, States must ensure that such measures do not impact on the quality and availability of services provided to the most vulnerable segments of society. 49. The independent expert stresses that considerable reductions in public sector staff and wages may severely impede the delivery of social services. Limited or decreased staff numbers, and reduction in remuneration to the providers of public services, particularly education and health care, could drastically impact on individuals’ ability to easily and effectively access such services. These measures may impact disproportionately on people living in poverty, particularly those in rural areas and the most disadvantaged, who already face numerous barriers in accessing health care and education services. By adopting such policies, Ireland may jeopardize its ability to enable the widest possible enjoyment of economic, social and cultural rights, and runs a risk of violating the prohibition against unjustified retrogressive measures. 35 36 37 12 Social Welfare Consolidation Act 2005, sect. 246. PGNR, p. 8. In 2009, 48.2 per cent of appeals were finalized in favour of the appellant. See Social Welfare Appeals Office, Annual Report 2009 (June 2010), p. 2.