Mary Dejevsky: These welfare reforms won't end our costly sick-note culture

It is highly doubtful that even after these changes, benefits in Britain will fall to the point where low-paid jobs become attractive without some form of top-up

Switch off the television lights and the advance sales pitch, and there was a very British reticence about how the Government presented its benefit reform bill. Iain Duncan Smith can argue his case with passion when he wants to, but he was not in zealot mode yesterday. Still less was David Cameron, who almost invited dissent by forecasting political battles to come. As a former correspondent in the United States when Bill Clinton's welfare reforms came in, I wanted to shout at the television: "Come on, guys: once more, with feeling..."

Official trepidation is understandable. Any government messes with benefits at its peril; especially one led by Conservatives still smarting from the public's affection for its forests. If you are broaching thoroughgoing reform of the sort that the Universal Credit potentially means, sweet reason, and an assurance that there will be no "cash" losers during the transition, may indeed be the wise approach. Stressing that almost 3 million people could gain, while far fewer would lose suggests that – unlike with the forests – everyone had done their homework.

I rather think, though, that Middle England could have stomached something stronger. The distinction between the Government's cool, incentives-driven approach (everyone will be better-off working), and the American fire-and-brimstone prescription (you will work, or else...) was striking. So was the long lead time: nothing at all will happen until 2013, with a majority of claimants – probably – inside the new system by 2016. That is five years and an election away: you are in government, guys, get on with it.

The United States is, of course, a very different society with very different assumptions, and there are many areas of the 1990s American welfare reforms that would not transfer here. This, at least, the Government has understood. Some of the distinctions emerged graphically when the BBC's Newsnight sent Lawrence Mead, one of the gurus of the US programme, to Liverpool.

In his report, broadcast earlier this week, he noted that although unemployment was high, Liverpool did not have the air of a depressed city – as it would do in the US. He omitted to conclude that this is largely because the social safety net is fixed higher. He also noted the extent to which those claiming benefits regarded the money as an entitlement; shorn of social censure or shame; it was something they were owed. This is debatable; less contestable is that working Americans have infinitely less sympathy for non-working Americans than British tax-payers do for (most) non-working Britons.

Such differences certainly aided the introduction of reforms in the United States that, from a British perspective, could seem ruthless. While exact arrangements varied from state to state, there were – and still are – reports of mothers having to rise before dawn, leave their children with a childminder, drive an hour or more (in an old banger supplied by charity) to a minimum-wage job – and back again. Like much about poverty in the US, such duress would be unacceptable here.

Generally, too, the level of welfare payments was, and remains, far lower in the United States – or paid in kind, through food stamps. This, too, facilitated reform. It is highly doubtful that even after the changes, benefits in Britain will fall to the point where relatively low-paid jobs will become attractive without some form of top-up. "Making work pay" in a low-wage, low-skills society (such as ours has become) is difficult, especially when it is believed that children should be cushioned from poverty. The fault here is less overgenerous benefits than unrealistically low pay; taxpayers are effectively subsidising employers.

Like the United States, we have a minimum wage. Unlike the United States, successive British governments have implicitly accepted that this is not enough for even quite a small family to live on. A family with at least one low-earner is likely to be better off on benefits. And the £25 a week by which IDS says people are guaranteed to be better off, will – I suspect – be nothing like enough. I heard several people interviewed yesterday who said, in essence, that a premium of even £50 a week would not be enough to compensate for the time that was currently "theirs".

And this highlights one lesson that could be transferable from the US – although it is not one the Government is "selling"– yet. A key element there was training in "job-readiness" – how to behave, how to dress, how to be organised enough to be employable. These and other courses included rigorous attendance requirements, without which benefits were stopped. Some states also introduced Workfare schemes, which made people work a fixed number of hours for their benefits. Here, ministers are tiptoeing around "conditionality". In time, refusing three jobs could result in the docking of – some – benefits for a maximum of three years. This seems on the unambitious side.

Like it or not, a reason why welfare rolls fell so spectacularly in the United States – indeed, the main reason, according to opponents of the reforms – is not because so many more people found jobs, but because the attendance requirements deterred so many from claiming. Here, the Government's desire to emphasise the carrot at the expense of the stick can be understood – at this stage – but the so-called "hassle factor" is set to remain mild. There seems no appetite for giving Jobcentres, or anyone else, an additional role as enforcers. Why not?

Something similar applies to the so-called sick-note culture. Those genuinely unable to work have been scared by lobbyists, supposedly on their side, that they will lose their allowances, even as two pilot schemes have shown how many recipients do not meet criteria for long-term disability. Is there not an argument now for accelerating the review process?

The US welfare reform offers two other lessons. The first is one that IDS, at least, clearly knows by heart: any reform worth the name will have a considerable upfront cost. There may be earlier pay-offs, in terms of social justice and national morale – but any savings to the Exchequer will take longer. The other, I am not sure has been absorbed, but is the oldest and most basic of all: when the buffeting starts, there is no substitute for political will.

m.dejevsky@independent.co.uk