Analysis of written responses to the consultation on social security in Scotland

7. Carer's Allowance

Proposals for a future Scottish Carer's Benefit

7.1 The Scottish Government set out its proposals for a future Scottish Carer's Benefit in Part 2 of the consultation document.

Question - Do you agree with the Scottish Government's approach to developing a Scottish Carer's Benefit? Please explain why.

Table 7.1 Do you agree with the Scottish Governments approach to developing a Scottish Carer's Benefit?
	Yes		No
Respondent group	Number	%	Number	%	Total
Individuals	84	92%	7	8%	91
Organisations	77	86%	13	14%	90
All respondents answering	161	89%	20	11%	181

Note: A full breakdown of responses by respondent group is included in Annex 2 (available to download separately as part of this publication).

7.2 A total of 181 respondents answered the closed part of this question. Most respondents (89%) agreed with the Scottish Government's approach to developing a Scottish Carer's Benefit. There was overall support from respondents from across respondent groups. Local authority respondents were more split than respondents overall, with a higher proportion (36%) disagreeing.

7.3 When asked to explain their response, 164 respondents provided further comments (97 organisations and 67 individuals).

7.4 The main themes emerging were:

• the level of the benefit;
• the impact on related benefits, paid employment and education; and
• the benefits of joint working.

The level of the Scottish Carer's Benefit

7.5 A large number of respondents commented on how to set the appropriate monetary level for a Scottish Carer's Benefit. Many broadly welcomed an increase in Carer's Allowance in the form of a Scottish Carer's Benefit.

7.6 Many supported this increase to the same level as Jobseeker's Allowance, but still had some reservations, mainly that this level of benefit would still be too low. A few respondents felt that the Jobseeker's Allowance level would not reflect the amount of work involved as a carer, and the fact that carers are already doing a full time caring role that prevents them looking for paid employment. There was some concern that the proposed increase still fell significantly below the minimum wage and living wage (at just over £2 an hour). A few wished to the see the Scottish Government choosing to use tax raising powers to increase the resources available, and to help lift many carers out of poverty.

"The poverty rate climbs the more hours per week spent caring."
Joseph Rowntree Foundation

"This still equates to slightly over £2 per hour, are we saying that this is now an acceptable level?"
NHS Lanarkshire

7.7 A few respondents felt that the increase should be treated as a minimum initial improvement, with a plan to uprate it over time. A few felt that a low level also indicated that the Scottish Government did not place enough importance on the work of a carer. However, a few felt that the increase, however small, was a symbolic recognition of the work that carers do. In addition, a few wanted to see a human rights approach adopted.

7.8 Some respondents commented on the savings generated for public health and social services by carers every year. Respondents pointed out that carers keep those they care for out of long term health care institutions, and that this should be recognised financially and otherwise. It was suggested that carers should receive an increase in their benefit level to reflect these resource savings.

"It is important that the Scottish Government recognises this enormous contribution as it develops its priorities for introducing a new Scottish Carer's Benefit, and makes a strong commitment to providing adequate financial support."
Midlothian Community Planning Partnership / Midlothian Council

"We are a hidden asset, largely ignored and deserve so much more."
Individual

The impact on related benefits, paid employment and education

7.9 A large number of respondents commented on issues around the impact of a Scottish Carer's Benefit on other benefits or activities. Some were concerned about the potential impact on reserved benefits such as Housing Benefit or Income Support, with many believing that an increase in Scottish Carer's Benefit might result in a reduction in their Income Support under the new Universal Credit rules. They felt that carers may be no better off, may have to navigate a confusing system and may experience administrative errors, delays and overpayments. A few felt that those on the lowest incomes would be most affected.

"We must ensure that any increase doesn't reduce entitlement to means tested benefits which are reserved to Westminster."
Rights Advice Scotland

7.10 A few felt that it was unfair that those in receipt of the state pension could not claim a Carer's Allowance, while others of working age could receive a Carer's Allowance and income support.

7.11 Some talked about the Carer's Allowance in relation to paid employment, with concern that the qualifying earnings threshold was too low - minimising opportunities for carers to take up other work opportunities. Some respondents said that any Carer's Benefit should remain non-means tested, as many carers had no choice but to reduce or give up work to carry out their caring responsibilities. Similarly, some respondents wanted to see the relationship between caring and studying revised. Respondents felt that carers should be encouraged to pursue personal goals and to develop the skills they would need to return to the labour market when their caring role ended.

"I sometimes get asked to work a little extra at work but I have to say no because my Carer's Allowance would be stopped."
MS Society Scotland

Caring time and for more than one person

7.12 Some felt that the '35 hour rule' of caring for the same person each week to qualify for Carer's Allowance was too restrictive. Some welcomed the Scottish Government's commitment to increasing Carer's Allowance for those looking after more than one disabled child. However, a few queried why this would not also be the case for those looking after more than one adult. A few felt that the consideration should be whether people are caring for more than one person, whether adults or children.

Joint working between services

7.13 Some talked about joint working between services, with some emphasising that while an increase in the allowance for caring is important, it was also important to think about other forms of social support. A few expressed a desire for more integrated services and support for carers, for example, through Health and Social Care Partnerships and through a wider network of support services for carers. However, a few (particularly local authority respondents) felt that more consideration needed to be given to the integration of delivery mechanisms for both the Scottish Carer's Benefit and the Carers Act 2016. A few welcomed the intention to improve the inclusion of carer voices in the design and development of support services.

"It must be remembered, especially for young carers, that support is not just about more money and access to and provision of other support services are equally important."
Bobath Scotland

Wider comments

7.14 A small number of respondents also highlighted issues around:

• Support for young carers - There was support for exploring a young carer's allowance, combined with an enhanced Job Grant payment, with a few commenting on the lack of availability of support and opportunities for young carers.
• Creating awareness of carer entitlements - A few respondents wished to see proactive targeting of carers eligible to claim benefits, to raise awareness of the available support.
• Eligibility criteria and assessments - A few respondents discussed the age limit for eligibility, the assessment process at local level, and the 84 day rule currently preventing families with a seriously ill or disabled child from receiving Disability Living Allowance once they have been in hospital for the same condition for more than 84 days.
• Health and wellbeing of carers - A few respondents emphasised the importance of looking after the wellbeing of carers, and the risk of poor health and wellbeing outcomes for carers if not addressed.
• Caring and gender roles - Given that the majority of carers in Scotland are women, a few expressed disappointment that the new approach did not take more account of gender and the impact that this can have on exacerbating inequality, particularly if a Carer's Benefit is set at a lesser rate than Jobseekers Allowance.
• The words used to describe the benefit - A few felt that words like allowance and benefit made them feel as if they were claiming from the state without providing anything in return.

Proposals for the short to medium term

7.15 The Scottish Government set out its proposals for the short to medium term priorities for developing a Scottish Carer's Benefit in Part 2 of the consultation document.

Question - Do you agree with our proposed short to medium term priorities for developing a Scottish Carer's Benefit? Please explain why.

Table 7.2 Do you agree with our proposed short to medium term priorities for developing a Scottish Carer's Benefit?
	Yes		No
Respondent group	Number	%	Number	%	Total
Individuals	72	90%	8	10%	80
Organisations	54	79%	14	21%	68
All respondents answering	126	85%	22	15%	148

Note: A full breakdown of responses by respondent group is included in Annex 2 (available to download separately as part of this publication).

7.16 A total of 148 respondents answered this question. Most respondents (85%) agreed with the Scottish Government's short to medium term priorities for developing a Scottish Carer's Benefit. Individuals were slightly more likely than organisations to agree. There was overall support from across most respondent groups. Local authority respondents were more split than respondents overall, with 36% disagreeing.

7.17 Further comments were provided by 105 respondents (64 organisations and 41 individuals).

7.18 The main themes emerging were:

• impact on other benefits and paid employment;
• support for young carers;
• advice and support;
• joint-up services; and
• advice, advocacy and support.

Impact on other benefits and paid employment

7.19 Some respondents supported an increase in the level of a Scottish Carer's Benefit, and some agreed that it should be raised to at least the level of Jobseeker's Allowance. A few said that an increased and more flexible Scottish Carer's Benefit would ensure that carers are recognised for their contribution to society and to cost savings for health and social care services.

7.20 However, a few respondents felt that the increase was not enough, as it would not meet the minimum income required to address financial hardship of carers. They believed that the Scottish Government should have an aspiration to increase the Carer's Allowance over time.

"The increased allowance of £11 per week will not make a meaningful difference to women's lives especially for those who are caring for children in addition to older, disabled or ill relatives."
Engender

7.21 Many respondents talked about an increased Carer's Benefit, and its potential impact on other benefits. A few respondents believed that Carer's Allowance should be treated separately from other benefits. They were concerned that an increased Scottish Carer's Benefit could mean that other non-devolved benefits may be reduced.

7.22 Some respondents talked about combining caring and paid employment. There was a general view amongst these respondents that the current earnings threshold should be removed or reviewed. These respondents said that the current earnings limit was too low, and didn't replace loss of income due to caring. This forced some carers to give up better paid work, made it more difficult for some to find suitable employment, or disqualified them from receiving Working Tax Credit or the Carer's Allowance.

"The Carers Allowance should be a benefit which replaces the potential earnings of those who are either unable work or have had to reduce the number of hours that they are available to work."
ENABLE Scotland

7.23 A few respondents said that enabling carers to take on paid employment more easily would have a positive impact on their health and wellbeing, self-esteem and social life. A few respondents like to see further development of the Carer Positive scheme, which encourages employers to support carers in their workplace.

Support for young carers

7.24 Many respondents discussed issues around young carers. Some welcomed the Scottish Government's plans to provide additional support and introduce a Young Carer's Allowance. A few had concerns about 'formalising' the role of young carers, as it should not be assumed or expected that a young person will willingly take on a caring role.

"Ideally, young people's caring duties should be reduced so they can take up the educational, employment and social opportunities available to other young people."
Orkney Islands Council

7.25 Some respondents called for the removal of restrictions around young carers, in relation to age, and for young carers in full time education or work. They felt that these eligibility criteria should be broadened, otherwise education, employment and life choices would be restricted in the longer term.

"Typically, full time students who do not have a caring role will supplement their incomes by way of part time or temporary work. For many young carers, however, their caring role means that this is not possible."
ENABLE Scotland

7.26 A few respondents wanted more clarity around proposed support for young carers. There was concern that the consultation document did not clarify at what age a young person would qualify as a 'young carer', as currently a carer under 16 cannot claim Carer's Allowance. A few respondents made suggestions about how to approach support for young carers, including:

• financial support, for example, grants for transport costs and leisure activities;
• more support services, for example, respite care and additional education tuition;
• a student grant for carers;
• protecting additional school supports such as means tested Education Maintenance Allowance and free school meals; and
• increased benefits for parents with disabilities to ensure that they are not forced to rely on their children for care.

Advice and support

7.27 A few respondents highlighted their concerns around advice and support for carers of disabled adults and children. They felt that they were being given the wrong advice about what their entitlements were. These respondents felt that additional support should be put in place for carers in these circumstances.

Joined up services

7.28 Some respondents wanted to see a more joined up approach in relation to all carers (including young carers). They felt that services for young people including health, social care and education should be supporting young carers in a more integrated and holistic way. The health and wellbeing of young carers was a concern for these respondents and they felt it was the role of Health and Social Care Partnerships to ensure this was a priority. Joined up services for adults were also discussed by these respondents. They felt that social security and health and social care services should be working together to provide a robust yet flexible package of support for carers.

"We also know that joined up holistic services and access to more flexible support, including goods and services will benefit the whole family."
Glasgow Disability Alliance

Advice, advocacy and wider support for carers

7.29 Many respondents discussed the importance of offering well-funded and easily accessed support services to carers. It was emphasised that carers should have the choice of support services where and when it suits them. These included person-centred information, advocacy and advice services, such as:

• additional tuition to maximise learning and education outcomes;
• respite, carer networks, centres and groups promoting socialisation and preventing isolation, perhaps delivered through the voluntary sector;
• a telephone helpline for carers in remote geographical locations;
• a national 'one stop shop' carer's advice service, signposting carers to appropriate support and providing Scotland-wide consistency;
• advice services on a range of issues, including finance and employment;
• advocacy support through representative organisations and networks;
• a simplified, user friendly, quick and supported application and awarding process, giving carers "dignity and respect";
• 'in kind' benefits such as reduced utility tariffs and discounted travel; and
• an awareness campaign to identify carers who are unaware of their status as a carer, their entitlement to benefits or of the wider advice and support available.

"Additional investment in carer support services is needed to ensure that support is available across the whole of Scotland, with particular focus on rural and remote geographies."
MS Society Scotland

Wider issues

7.30 Some respondents highlighted wider issues in relation to this question:

• voluntary alternatives to cash payments;
• ensuring that the approach to a Scottish Carer's Benefit is developed in line with wider strategy and policy, such as health and social integration and the Carers (Scotland) Act 2016; and
• implementing change incrementally to avoid a shock to the system and to claimants.

Question - How can we improve the user experience for the carer ( e.g. the application and assessment process for Carer's Benefit)?

7.31 In total, 114 respondents answered this question: 67 organisations and 47 individuals.

7.32 The main themes emerging were:

• pre-assessment information, advice and support services;
• the application and assessment process for carers; and
• eligibility criteria for receiving the Scottish Carer's Benefit.

Information, advice and support services

7.33 Many respondents discussed the importance of pre-application information, advice and support services for carers. Some suggested additional support and advice services that would be useful, including:

• a carers support telephone line;
• peer support groups and access to respite, for adult and young carers;
• concessionary travel;
• accessible online information, for example, relevant links on the Scottish Government website;
• joined up support through integrating services, such as the development of an online carer's portal, or 'one stop shop' allowing people to access all the financial, resource, support and advocacy information they need; and
• national promotional campaign around carer's entitlement, to engage those who don't, but who are eligible, to claim.

"More carers support groups are necessary. This type of support can be invaluable in helping individuals to complete application forms, which can be confusing and complicated."
Scottish Women's Convention

7.34 A few respondents talked about the consequences of poor pre-application information. They felt that unpaid carers must be proactively identified.

"Be transparent. Carers need to know they are valued and supported and have information about all of their options."
Bobath Scotland

The application and assessment process for carers

7.35 A large number of respondents commented on the application and assessment process. Some felt that the current application and assessment process for Carer's Allowance was reasonably straightforward, in comparison to other benefits. A few respondents did not believe that it required any change, but must continue to prioritise and value the carer and cared for person.

7.36 A large number of respondents who were quite satisfied with the application and assessment process still felt improvements could be made. Speed of decision making and simplification of the process were particularly highlighted. Improvements suggested included:

• reducing the length of time between making a claim and receiving payment;

• Involving carers in the design of application and assessment processes to ensure they best fit the needs of the people using them.
• Developing a single integrated assessment which considers carers' needs in a holistic way, giving carers the choice over how their support is provided.

• Making a range of paper-based, telephone, face to face and online claims easily accessible.

• Revising application forms and processes so that they are simpler and easier to understand, including an Easy Read option.
• Introducing free phone numbers for carer enquiry lines.
• Employing claims assessors who are well trained and knowledgeable with an understanding of caring, to make the process less impersonal.
• Including carers on the Claimant Panel.
• Regular communication with the claimant at all stages of the process.
• Ensuring that any changes to a carer's eligibility criteria does not complicate or delay the application process.
• Clearer procedures for carers who wish to challenge decisions to stop or refuse payments.
• A well-designed monitoring and evaluation framework to ensure the system is fit for purpose, identify any issues and continually improve the service where required.

"Carers don't have time for multiple calls and completing extremely long forms."
Carers Trust Scotland

7.37 Some respondents had more serious concerns about the current application and assessment process. These were wide ranging and included issues around inadequate communications and administration:

• Issues with communication about claims for Carer's Allowance. For example, lengthy telephone hold times;
• Reporting changes in circumstances could be complicated, resulting in delays and overpayments; and
• Lack of joined up working between services where information could be shared, with consent, about carers and those they care for to make the application and assessment process simpler.

"At present, application and assessment processes for carers benefits are unnecessarily long and arduous."
Scottish Women's Convention

Eligibility criteria for receiving the Scottish Carer's Benefit

7.38 Many respondents expressed concern about eligibility criteria. For example:

• UK-Scotland links - Some respondents were concerned about the potential for tensions between the Scottish Carer's Benefit and other reserved benefits, in case the existing overlapping rules meant that they could not receive carer entitlement, or reduced other benefits. They felt that benefits for carers and those cared for should be separated, rather than each dependent on the other, and that a system streamlining the interaction between different benefits should be in place.

• Clarity - Revising any unclear information about eligibility criteria.

• Timescales - Difficulties in claiming Carer's Allowance because of delays including re-assessments in the payment of PIP and DLA awards for the people they cared for, or the Scottish Carer's Benefit process becoming lengthier and more complicated.

• Restrictions - Limitations around carers in employment were noted by a few respondents, who felt that the earnings limit should be raised and that many carers are living in poverty. A few respondents mentioned the need to remove restrictions around caring and full time study.
• Evidence - A few respondents felt that carers should have to evidence that they cared for some for at least 35 hours a week.

"Ensure that the rules are not ambiguous and are precise in their definitions."
Carers Scotland

"Above all, treat people as individuals, with dignity and respect."
Aberdeen Action on Disability

Question - Should the Scottish Government offer the choice of exchanging some (or all) of a cash benefit for alternative support ( e.g. reduced energy tariffs)? Please explain why.

Table 7.3 Should the Scottish Government offer the choice of exchanging some (or all) of a cash benefit for alternative support ( e.g. reduced energy tariffs)?
	Yes		No
Respondent group	Number	%	Number	%	Total
Individuals	40	56%	32	44%	72
Organisations	29	54%	25	46%	54
All respondents answering	69	55%	57	45%	126

Note: A full breakdown of responses by respondent group is included in Annex 2 (available to download separately as part of this publication).

7.39 A total of 126 respondents answered this question (72 individuals and 54 organisations). Views were fairly split with just over half of respondents (55%) feeling that the Scottish Government should offer the choice of exchanging some (or all) of a cash benefit for alternative support. A fairly split position was observed across most respondent groups.

7.40 When asked to explain why, 116 respondents commented further on this question (61 organisations and 55 individuals). Many felt it would offer choice, flexibility and control.

Choice

7.41 Many respondents emphasised that carers should be given the choice over how they would prefer to receive their benefit. They believed that a cash payment should be the default, and carers could then choose if they would prefer an alternative to cash. A few felt that it should be a voluntary and genuine choice, which would not reduce access to other benefits.

"Being able to make the choice would demonstrate the Scottish Government's commitment to ensuring the dignity and respect of those claiming Carer's Allowance."
Scottish Women's Convention

Flexibility and control

7.42 Many respondents felt that offering alternatives to carers provided them with greater flexibility and control. They believed that this may suit some carers, would make the best use of resources available and could ensure that the benefit was tailored to meet individual needs. There was some interest in discounted energy and utility bills, which some felt could reduce fuel poverty and allow the carer to focus more of their time on the person they care for.

"This may enable people to manage / budget their money better whilst providing a more useful alternative to cash for many."
Fife Council

7.43 A few respondents felt that it would be useful to consider other discounts including discounted travel costs, food bills, fuel bills, clothing and equipment, such as mobility scooters.

No alternatives should be offered

7.44 Some respondents did not agree that there should be alternatives to cash payments. A few felt that offering vouchers was "stigmatising". Some respondents felt that discounted goods and services should be offered and delivered separately from social security benefits.

"Everyone who cares should receive Carer's Allowance - the choice of what they want to do with it is up to them."
Parkhead Citizens Advice Bureau

7.45 A few respondents declined to answer 'yes' or 'no' to this question, as they felt they had not been given enough information about how such a system would work.

Question - What alternative support should be considered?

7.46 In total, 83 respondents answered this question (43 organisations and 40 individuals). A large number of respondents said that carers required more than just financial support, and should be offered a range of services - designed in consultation with carers.

"Carers should be consulted on the type of support they require and how it can be provided."
North Ayrshire Council

Goods and services

7.47 Some respondents were interested in:

• Respite - Access to free or affordable respite care and discounted short breaks, leisure and sports activities. Some respondents discussed the importance of carers getting a break, whether an evening at the cinema or a week on holiday.
• Bills - Some respondents discussed discounted utility bills for carers. For example, they felt that energy costs for carers should be discounted. Some of these respondents also believed that carers should be offered Council Tax Reduction, and discounted telephone and internet tariffs.
• Travel - Some respondents highlighted the importance of discounted travel costs including bus passes, and Motability for disabled claimants. They felt that this should particularly apply where the carer does not live with the person they care for. Respondents said that discounted travel should be available to carers whether or not they were with the person they care for.
• Adaptations - A few respondents said that access to a service for housing adaptations and repairs for carers would be useful.
• Health - A few respondents talked about free health costs for carers, including optical and dental treatment, and discounted food and clothing.

7.48 Respondents felt that some services such as free bus passes and relaxation therapies could have significant positive impacts on the health and wellbeing of carers.

Wider support

7.49 Many were interested in services to help reduce isolation and build confidence and self-esteem. A few respondents talked about the importance of carer support organisations. They believed that the Government should invest more funding into new and existing carer support groups and agencies as these are often the main source of support for carers, offering employment, financial, housing and other assistance. A few respondents felt that there should be better signposting to relevant services for carers around the country, and better transition support once they had reached the end of their caring journey, especially for those who have given up work to care for someone.

"What happens when caring stops?" As women, we lose pension rights and returning to work becomes hard."
Engender

7.50 Again, respondents emphasised the importance of effective signposting to the appropriate support organisations, which could perhaps be achieved through a dedicated registration system.

"Rather than looking at alternative support, the Scottish Government should consider what additional support they can provide for carers."
The Poverty Alliance

Question - How can we achieve a better alignment between a future Scottish Carer's Benefit and other devolved services?

7.51 In total, 87 respondents answered this question (32 individuals and 55 organisations).

7.52 The main themes emerging were around:

• national level administration;
• local level administration;
• developing and signposting to carer support mechanisms; and
• consultation with carers.

National level administration

7.53 Some respondents stated that establishing central administration for devolved services, through a body such as the new Scottish social security agency, would be the most effective way of administering a Scottish Carer's Benefit.

7.54 A few respondents also raised concerns about potentially delivering a Scottish Carer's Benefit through local authorities. They said that the budget for the new Carer's Benefit should not be merged with social care budgets. One respondent said that the Scottish Government performance in this area could be linked to and measured by the National Performance Framework and outcomes. Another said that the new Carer's Allowance should be closely aligned with the Scottish Carers (Scotland) Act 2016.

"Achieving positive outcomes for both carers and the individuals they care for must be seen as a desired national economic investment. This would require a holistic approach including reducing fuel poverty and tackling social isolation."
Scottish Council for Voluntary Organisations

"We share concerns about the potential implications of integrating social security and social care services. However, it is imperative that budgets to support carers remain distinct from social care budgets at local authority level, and that the Scottish Carer's Benefit is administered by the new, central agency."
Engender

7.55 A few respondents talked about the need to improve communications between the DWP and devolved services. They said that information sharing between the two would be essential. A few respondents felt that aligning a Scottish Carer's Benefit and other devolved services could be difficult, because currently entitlement to Carer's Allowance impacts on the existing premiums of reserved benefits. These respondents felt that reserved benefits which might be affected by the new Scottish Carer's Benefit, such as Self Directed Support, must be protected.

Local level administration

7.56 Some respondents talked about the need to have devolved Scottish social security benefits including the new Scottish Carer's Benefit under the control of integrated health and social care services within local authorities.

"Local Government delivery could mean a wrap-around approach to service delivery at the earliest opportunity."
Perth and Kinross Council

7.57 A few respondents said that to ensure the success of local level approaches, information sharing between the Scottish social security agency, health, social work and other public services would need to be improved. Local offices or 'one stop shops' staffed with knowledgeable people would be required to offer practical support.

"The integration of the HSCP should allow better information sharing and joined up working at the local level. The important issue will be how the system can recognise

that a person is undertaking the role of a carer in the first instance, and then ensure that all relevant agencies are aware."
East Ayrshire Council

Developing and signposting to carer support mechanisms

7.58 Some respondents believed that appropriate support mechanisms were as important for carers as social security benefits. Respondents said that the devolution of Carer's Benefit offered the opportunity to signpost and refer carers to support services as soon as a benefit application is made. Similarly, people using carer's support services who do not already claim Carer's Benefit, could be made aware of this entitlement and services could be automatically alerted if a person's circumstances change.

"There are many good carer groups out there but not everyone finds them."
Citizens Advice Scotland

7.59 Other respondents talked about the need for the development of a single portal or point of contact for accessing all financial and other carer support. They felt that it would simplify the process of accessing support for carers, allowing financial and other resources to be pooled in a holistic way.

"The systems and processes in place to deliver self-directed support have significant potential in this respect."
COSLA

Consultation with carers

7.60 A few respondents said that consultation with carers was the best way to find out how best to achieve a better alignment between a future Scottish Carer's Benefit and other devolved services. These respondents felt that consultation should take place with carers, people who are cared for, those delivering carer's support services and any relevant partner agencies.

"The ethos adopted throughout the development of the strategy should be that carers should be partners in the plan."
One Parent Families Scotland

Question - How can we improve the support given to young people with significant caring responsibilities - beyond what is currently available?

7.61 In total, 60 respondents answered this question (29 individuals and 31 organisations).

7.62 The main themes emerging were:

• general views on Young Carer's Allowance;
• availability of non-financial, wider support;
• access to education and employment for young carers;
• identifying young carers; and
• supporting young people out of their caring responsibilities.

General views on Young Carer's Allowance

7.63 Some respondents talked generally about the proposed Young Carer's Allowance. Most felt that there is a need to reach beyond what is currently being provided.

"According to the Scottish Government, there are currently 44,000 carers under the age of 16 in Scotland and it is estimated that in monetary terms, the care they provide is worth in excess of £300m."
Children and Young People's Commissioner Scotland

7.64 Respondents talked about how a Young Carer's Allowance should be administered. Some felt that a direct cash payment would be acceptable. There were varied views about whether this payment was made directly to the young carer, or to the person they care for. Some said that this should not have a negative impact on other benefits like EMA or Child Benefit. Others thought that a voucher scheme might me more appropriate. A few said that any financial benefit for young carers should consider assistance with housing costs. A few felt that they needed more detail on what the scheme would entail, before they could make an informed judgement.

7.65 Concerns were raised about whether young carers under the age of 16 should receive a Young Carer's Allowance. It was suggested that payments could be made into a trust fund for young carers to access when they got older. Others felt that young carers might not have the maturity to manage an allowance effectively, or the person they cared for may feel that the allowance should be given to them, particularly when caring for someone with an addiction.

Availability of non-financial, wider support

7.66 Many respondents talked about improving the support for young people with significant caring responsibilities. Generally, these respondents welcomed the idea of better support, however, they were not sure that a financial payment was the right approach to take.

"We do not think that a financial allowance for young carers is feasible."
Parkhead Citizens Advice Bureau

7.67 Respondents echoed concerns around giving cash payments directly to young people, especially under the age of 16. Other respondents felt that young carers required a package of support, which may or may not include a cash payment. They felt that investment in young carer support services would be more worthwhile, including:

• access to respite and short breaks / holidays;
• free or discounted access to leisure facilities;
• more skills and personal development projects aimed at young carers;
• concessionary transport;
• help in the home;
• extra support from social work, mental health and education services;
• alternative education, for example, remote learning packages;
• access to counselling, mentoring and peer support opportunities; and
• rolling out the Young Carer's Charter. ^[5]

7.68 It was suggested that greater collaborative working with third sector partners would be required to deliver non-financial packages of support for young carers.

Access to education and employment for young carers

7.69 A few respondents welcomed the idea of removing restrictions on young carers in full time education. Respondents said that many young carers were prevented from claiming Carer's Allowance because they studied or worked alongside caring.

"Removing or changing the rules related to the earnings threshold and studying would support this cohort without the need for a separate Young Carer's Allowance."
Scottish Council for Voluntary Organisations

7.70 Citizen's Advice Scotland highlighted a Scottish Youth Parliament public petition to the Scottish Parliament in 2013, suggesting the development of a Young Carer's Grant for those in full time education or under 18, who were not eligible for Carer's Allowance. The idea behind this grant was to support the health and wellbeing of young carers throughout their studies and prevent them from dropping out.

7.71 Respondents questioned why young carers should have to sacrifice achieving qualification and skills for the future, because they have caring responsibilities. These respondents felt that this creates a barrier to employability and a potential group of unskilled working age people in the future.

Identifying young carers

7.72 A few respondents talked about developing better processes to identify young carers before being able to decide what additional support they might require. Respondents said that currently there were issues in identifying young carers, partly because not all young carers have a Young Carer Statement or Support Plan, so many go unrecognised. They felt that cross referrals with health, social care, education and housing were required, as many young carers are socially isolated and disadvantaged. A few suggested the introduction of incentives for GPs to register young carers.

"There are additional barriers for young carers who may be eligible for support, such as the family's fear that children will be taken into care, so they are often 'hidden' from health, social care and education services."
Action for M.E.

Supporting young people out of their caring responsibilities

7.73 A few respondents said that the Scottish Government should be placing more focus on establishing a route out of caring for young people. They felt that by developing a Young Carer's Allowance, this might pressurise young people to continue with caring, and prevent them from considering alternative future possibilities. Respondents suggested that by investing more in adult carers, there would be less need to rely on young carers.

Proposals for the longer term

7.74 The Scottish Government set out its proposals for the longer term in Part 2 of the consultation document.

Question - Do you agree with our proposed long term plans for developing a Scottish Carer's Benefit? Please explain why.

Table 7.4 Do you agree with our proposed long term plans for developing a Scottish Carer's Benefit?
	Yes		No
Respondent group	Number	%	Number	%	Total
Individuals	73	92%	6	8%	79
Organisations	57	88%	8	12%	65
All respondents answering	130	90%	14	10%	144

Note: A full breakdown of responses by respondent group is included in Annex 2 (available to download separately as part of this publication).

7.75 A total of 144 respondents answered this question. Most respondents (90%) agreed with the Scottish Government's proposed long term plans for developing a Scottish Carer's Benefit. There was overall support from across respondent groups.

7.76 Further explanation was provided by 104 respondents (38 individuals and 66 organisations).

7.77 The main areas discussed were:

• definition of a carer and eligibility criteria;
• level of the Scottish Carer's benefit; and
• implementation processes and timescales.

Definition of a carer and eligibility criteria

7.78 A large number of respondents focused on eligibility criteria. Many said that the differing definitions of carers currently used were confusing. These respondents welcomed the Scottish Government's long term aim of widening the definition of a carer under the Carers (Scotland) Act 2016, but felt that this needed to be communicated clearly.

"The definition of a carer is simply someone who provides care for someone. Any alteration to this definition to exclude people who provide care should be opposed."
Individual

7.79 Most felt that the benefit needed to remain non-means tested. Most said that there was a need to review the eligibility for Carer's Benefit, as currently it was too restrictive. These respondents felt that many carers were losing out on much needed payments as a result. A few of these respondents said that as part of the re-classification of Carer's Benefit in Scotland, the overlapping rules should be disregarded.

"We need to be aware of how any changes we make might impact on reserved benefits. Giving with one hand and taking away with the other is of little use."
Angus Community Planning Partnership, in co-operation with the Angus Welfare Reform Group

7.80 Respondents raised a range of issues relating to eligibility, including:

• enabling carers to receive Carer's Benefit while studying full time (more than 21 hours per week) or earning more than £110 per week;
• allowing carers of any age to claim Carer's Benefit - with the overlapping rule meaning that carers cannot claim Carer's Allowance as well as the state pension being seen as unfair, and support for young carers under 16 receiving a Young Carer's Benefit;
• considering introducing a two-tier payment structure for carers with a lower and higher rate of award. For example, a universal level plus additional payment to carers on the lowest incomes, and those caring for people with more complex needs, as an earnings replacement benefit or higher carer premium; and
• removing the rule that means Carer's Allowance is stopped if the person they care for is admitted to hospital for a prolonged period.

"The stopping and starting of CA currently leads to serious problems for claimants."
One Parent Families Scotland

"Removing the connection between Carers Allowance and qualifying disability or ill health benefits would be beneficial for many carers who are looking after someone who does not qualify for the benefits but still needs to be looked after."
Carers Scotland

Level of the Scottish Carer's benefit

7.81 Some respondents said that while the increase in Carer's Benefit was welcome, it did not go far enough. It was suggested that the Scottish Government should work towards paying carers a Living Wage. Most of this group of respondents believed that the current Carer's Allowance did not enable a carer to be financially independent or socially included.

"We believe that there is further work to be done in establishing whether the level proposed by the Scottish Government is enough, as effectively it falls well below the minimum wage."
Public and Commercial Services ( PCS) Union

7.82 Related to this, some respondents felt that people who care for more than one adult or child should receive a Carer's Benefit for each of those individuals. Similarly, it was suggested that two people caring for one person who requires 24-hour care should each be able to claim Carer's Benefit.

"The level of Carers Allowance should not be based on how many people you care for. It should be based on the level of disability and complexity of need / care required for the individual."
Individual

Implementation processes and timescales

7.83 Some respondents talked about the implementation of a new Scottish Carer's Benefit. They discussed what the model might look like, commented on proposed timescales, or on potential administrative costs of setting up such a system (mainly local authority respondents).

7.84 A few respondents emphasised the need to ensure effective communications between the DWP and the devolved Scottish benefits system, otherwise there could be administrative errors, delays and overpayments. A few respondents talked about the need to be mindful of data security, especially when sharing personal and sensitive information between agencies.

7.85 Some felt that change should happen as quickly as possible, with a few suggesting changes before the establishment of a new social security agency.

"Carers whose opportunities, wellbeing, income and future pensions are being eroded by current restrictions to Carer's Allowance should not have to wait for years on end for a fairer system when the Scottish Government could take action now."
Engender

7.86 A few respondents said that the new system had to be well-publicised to address historically low take up rates of Carer's Allowance.

"Proactive efforts must be made to identify carers so they are aware of their support entitlement."
Scottish Council for Voluntary Organisations

Question - Do you have any other comments about the Scottish Governments proposals for a Scottish Carer's Benefit?

7.87 In total, 94 respondents answered this question (40 individuals and 54 organisations). Respondents largely reiterated earlier points.

Education and employment

7.88 Some respondents reiterated points made in previous questions about:

• the earnings threshold for carers claiming Carer's Benefit should be higher than £110 per week;
• carers being forced out of work or having to reduce their hours and rates of pay to combine work and caring; and
• that being a carer should not be a barrier to gaining an education.

7.89 A few of these respondents said that providing increased access to respite might allow carers more time to study while caring. Respondents felt that this was particularly important in relation to young carers.

Proposed level of the Scottish Carer's Benefit

7.90 Some respondents reiterated concerns over the proposed monetary level of the new Scottish Carer's Benefit. Within this group, some pointed out that caring is a job that many haven't chosen, feeling that the new Scottish Carer's Benefit won't meet minimum living standards and reiterating that it should vary with the needs of those being cared for. Some reiterated an interest in a two-tier system, with higher payments for some.

Scottish Carer's Benefit and non-devolved benefits

7.91 Some respondents expressed concerns over the interaction between the new Scottish Carer's Benefit and reserved benefits. A few pointed out that an increase in Scottish Carer's Benefit could mean that other benefits such as Income Support and the Severe Disability Premium are reduced. It was suggested that the Scottish and UK social security systems will always be inter-twined, therefore any changes made to devolved benefits must be carefully scrutinised.

"Is there any scope the Scottish Carer's Allowance could be legislated to be deemed wholly disregarded as income for all benefits, including those administered by UK Government?"
Prospect Community Housing

Caring for more than one person

7.92 Some respondents reiterated that carers who care for multiple people should be able to claim a greater amount of Carer's Benefit, while others reiterated that caring for two people with moderate needs might be less intensive than caring for one with more intensive needs.

"Caring for more than one person is more expensive as well as more difficult and stressful, and people in this situation are much less likely to be able to undertake paid employment alongside caring."
Carers Scotland

Age restrictions

7.93 A few respondents talked about the age restrictions currently placed on some carers from claiming Carer's Benefit - for either being too old, or too young. However, some reiterated that more money should be invested into adult caring, to reduce expectations around young people becoming carers in the first place.

Wider support services

7.94 A few respondents mentioned the importance of wider support services for carers. They felt that the Scottish Government must commit to investing in and strengthening these services, to enable carers to seek assistance how, when and where they need to.

Assessment process for carers

7.95 A few respondents discussed the assessment process for carers, with a few reporting negative experiences. These respondents said that comprehensive needs assessments of carers and those they care for should be provided, to ensure that they are receiving the right level of support and not at risk of social isolation.

"Forms are far too long and complicated. Online, face to face and phone applications should be considered."
Engender

Transitional arrangements for carers

7.96 A few respondents felt that Carer's Benefit should be tapered, rather than immediately stopped, for carers whose circumstances change. Additionally, Carer's Allowance stops eight weeks after the death of the person cared for, and this can be an abrupt transition for someone who may have cared for a significant time. A few respondents said that a holistic approach should be developed to supporting carers when their caring responsibilities come to an end. This should include employability, education, leisure and health and wellbeing agencies.

7.97 Respondents also talked about instances in which the person being cared for is admitted to hospital for longer than 28 days, and their disability payment stops. This means that Carer's Allowance stops at the same time. This 'stopping and starting' of Carer's Allowance was seen as unfair, and a sudden drop in income would place additional pressures on carers.

Health and wellbeing of carers

7.98 A few respondents discussed the fact that the health and wellbeing of carers was often overlooked. A few felt that this breached the human rights of carers, and those they care for.