validity of invitation to claim PIP

My client was getting DLA mobility. He went to renew his motability car, but as his claim had less than 12 months to run, he was advised to request an extension of the award. The DWP invited him to claim PIP. His claim was promptly refused and he lost his car and the remaining few months of his DLA award. He has appealed against the PIP refusal, but I’m wondering if we should argue that he shouldn’t have been asked to claim PIP in the first place, on the basis that he didn’t declare a change of circumstances, he just asked for his DLA mobility to be extended (PIP (TP) Reg 3). I suspect once the PIP2 form is completed that arguement may be invalidated by Reg 4, but I’d welcome any thoughts.

I’ve looked long and hard at this and agree with you that he shouldn’t have been invited. The TP regs define a change of circs such as would trigger an invitation to be a change that is likely to mean a change of component. “Please extend my award” isn’t such a change.