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

9. Funeral Payments

What should the benefit cover?

9.1 The Scottish Government set out its proposals for what the benefit should cover in Part 2 of the consultation document.

Question - Which of these elements do you think should be paid for by the Funeral Payment?

Table 9.1 Which if these elements do you think should be paid for by the Funeral Payment?
	Element	% of respondents
		Yes	No
Mostly supported	Removal or collection of the deceased	99	1
	Care and storage	99	1
	Coffin	98	2
	Hearse or transport	98	2
	Professional funeral director fees: advice and admin	94	6
	Fees associated with the ceremony	86	14
	Travel expenses to arrange / attend funeral	69	31
Mixed views	Memorial headstone / plaque	56	44
	Limousines or cars	48	52
	Death notice	46	54
Mostly unsupported	Order of service	36	64
	Flowers	36	64
	Venue hire	23	78
	Catering for wake / funeral	22	78

9.2 A total of 156 respondents answered this question (72 organisations and 84 individuals). The question listed 14 elements for respondents to decide if they should, or should not, be included in the Funeral Payment benefit. The table above provides an overview of which elements were largely supported, unsupported, or where there were mixed views.

9.3 The elements there was most support to include were:

• removal or collection of the deceased;
• care and storage of the deceased before the funeral; and
• hearse or transport; and professional funeral direct fees.

9.4 There were mixed views around the inclusion of some of the other elements in the Funeral Payment benefit. These included the provision of limousines, a headstone or plaque and the death notice.

9.5 The elements that respondents most strongly felt should not be included in the Funeral Payment benefit were venue hire and catering for a wake / funeral reception.

Question - Are there other elements that you think should be included or explicitly excluded? Please explain why.

Table 9.2 Are there other elements that you think should be included or explicitly excluded?
	Yes		No
Respondent group	Number	%	Number	%	Total
Individuals	18	31%	41	69%	59
Organisations	31	50%	31	50%	62
All respondents answering	49	40%	72	60%	121

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

9.6 A total of 121 respondents answered the closed part of this question. Over half of respondents (60%) did not think there were other elements that should be included or explicitly excluded. However, a significant minority (40%) did. Organisations were slightly more likely than individuals to answer 'yes'. Those answering 'yes' came mainly from local authority respondents and organisations in the funeral group respondents.

9.7 Further comments were provided by 81 respondents (34 individuals and 47 organisations). Comments mainly came from those who answered 'yes' to the closed part of the question, or didn't answer it at all.

Additional elements for inclusion

9.8 Many respondents who said 'yes' suggested additional elements to the list provided in the consultation document. Suggested elements for inclusion in the Funeral Payment were:

• disposal costs;
• dressing of the body and viewing of the deceased;
• death certificate and additional copies;
• language and communications support for people with communication difficulties;
• taking the deceased home to rest;
• church fee, session clerk or organist;
• embalming and hygienic treatment;
• burial plot; and
• childcare.

9.9 Some of these respondents, most notably local authority respondents, believed that additional costs might be incurred for medical, religious or cultural reasons. For example, a pacemaker may have to be removed prior to cremation.

"Respect for a person's religion or beliefs is a basic principle in our country and the state should assist a family in observing any relevant practices."
Society of Allied Independent Funeral Directors ( SAIF) Scotland

9.1 9.10 A few respondents talked about the need for a contingency fund to be put in place to cover additional costs in the event of unusual deaths. Such circumstances could include when an inquest is held, where clean up is required after a violent death or where the next of kin is not UK-based.

Suggested exclusions

9.11 Respondents who answered 'yes' also suggested exclusions in their comments. These exclusions included elements already considered in the closed part of this question. The main exclusions identified in comments were:

• flowers;
• limousines, or cars for anyone other than immediate family;
• death notice in local newspaper;
• order of service sheets;
• catering or a venue for the wake;
• memorial headstone or plaque; and
• routine embalming.

9.12 A few respondents explained their reasoning for excluding certain items from the list in the consultation document. For example, a reception or wake could be held at the home of someone related to or close to the deceased. Order of service sheets could be printed at home, and hiring several cars to transport family, carers and friends could be replaced by a minibus. These respondents felt that only collection, storage and cremation or burial of the body were essential costs. All others they felt were non-essential and not reasonable to expect taxpayers to cover.

Standardising costs

9.13 Some respondents, mainly those who answered 'yes' to the question, talked about the requirement of a Funeral Payment to cover basic, fixed cost funerals. Respondents had slightly different views on what the essential elements of a basic funeral were and how this should be covered.

• A few respondents felt the average cost of a funeral should be established - including all elements - and the Funeral Payment grant set at a level which is a proportion of that sum (to cover the essential elements).
• A few respondents felt that a fixed cost payment would allow families to better understand the costs of a funeral and what the payment should and should not cover.

9.14 A few respondents (the majority of whom answered 'yes') said that the current level of the DWP Funeral Payment was too low. They pointed out that the Funeral Payment only covers part of the cost of a funeral, while families have to find the funds to meet the rest.

"The current DWP payment (capped at disposal costs plus a small allowance for extras) does not meet the full cost of a funeral on most occasions."
Citizens Advice Scotland

9.15 A few respondents also discussed setting a reasonable cap for costs on an agreed list of essential elements. They felt that a list of fees should be developed by funeral directors and the Scottish Government. Some felt that interest free loans could be provided to families and carers for non-essential elements.

9.16 It was suggested that the Scottish Government should focus on its wider funeral poverty work, by engaging with local authorities to look at the variations in fees charged across the country. It was felt that funeral charges should be reduced or at least prevented from increasing in the future, and that the Scottish Government should be taking steps to regulate funeral fees.

9.17 Other suggestions of how to standardise funeral costs covered by the Funeral Payment (made by those who answered 'yes' and 'no') included:

• using a standard wood coffin, furnished to a basic standard, defined by the Scottish Government in conjunction with funeral directors;
• using a standard hearse as opposed to alternative modes of transport such as a horse-drawn carriage, or limousines; and
• developing state funeral offerings as an alternative to packages from private providers, to help drive costs down.

Individualised funerals providing dignity and respect

9.18 A few respondents (both those who answered 'yes' and 'no') talked about the importance of providing state-funded funerals which, above all, promoted dignity and respect. A few respondents who answered 'no', said that itemising a funeral was not person-centred, or that providing a list of essential elements for inclusion was too prescriptive, as families and communities place different values on different elements of a funeral ceremony. A few who answered 'yes' believed that no-one should be denied a meaningful and dignified funeral. This included the costs involved in respecting the requirements of different faith groups.

"The payment, as a minimum, should cover the immediate and essential requirements of providing a respectful funeral."
Humanist Society Scotland

9.19 Respondents also talked about funeral poverty and lower income families. They felt that full expenses for a dignified simple funeral should be provided. High funeral costs can leave low income families vulnerable to loan sharks and other forms of high interest borrowing.

"Bereavement is frequently a trigger for debt amongst low income families who struggle to cope with the financial impact of bereavement at a time when they are most emotionally vulnerable."
Perth and Kinross Council

Reasons for answering 'no'

9.20 Of those respondents who answered no to the closed part of this question, a range of points were made. A few felt that itemising funeral costs did not provide either the deceased or the bereaved with dignity or respect. A few argued that funerals should be individualised, treated on a case by case basis, or that each element should be considered within the context of different cultures and traditions. Others said that the elements outlined in the consultation document were satisfactory, or that state funerals should be as basic and simple as necessary.

Eligibility

9.21 The Scottish Government set out its proposals for eligibility in Part 2 of the consultation document.

Question - How can we improve the process for identifying whether someone is responsible for the funeral and should receive the funeral payment?

9.22 A total of 113 respondents answered this question (67 organisations and 46 individuals).

9.23 The main themes that emerged from the responses were:

• the application and identification process;
• eligibility requirements for those receiving the Funeral Payment;
• linking the Funeral Payment directly to the deceased;
• sensitivity and respect;
• Funeral Payment fraud; and
• information and advice.

The application and identification process

9.24 Some respondents talked about the need to develop a defined system for identifying who should receive a Funeral Payment. Some felt that the current application and identification system was too lengthy, complex or unfair. A few respondents stated that the application system needed to be clearer and more transparent, but did not see any immediate issues with the identification process.

"The long process endured before receiving a decision on a Funeral Payment is stressful in itself but can also delay the funeral taking place."
Society of Allied Independent Funeral Directors ( SAIF) Scotland

9.25 Other respondents did have concerns about identifying the person responsible for the funeral. Suggestions included:

• Incorporating this process into the wider social security system - For example, individuals completing forms for other benefits could at that point nominate one person who they would like to be responsible for their funeral, which would make the process more person-centred.
• Involving funeral directors - A few felt that funeral directors were best placed to identify who is responsible for the funeral and assist bereaved people to complete the application form. It was felt that they could identify who should receive the payment quickly and sensitively. A few respondents suggested that direct payments to funeral directors would speed up the process.
• Involving local authorities - A few respondents suggested that local authorities would be best placed to administer the process and payment, because they would already have the deceased's and potentially the applicant's information. The local authority could act as a single point of contact for the bereaved and signpost to the appropriate services.
• Simplifying the criteria - Citizens Advice Scotland recommended using a 'nearest relative test', which is currently used in the Human Tissue (Scotland) Act 2006. This is the test recommended by the Burial and Cremation Review Group. Other respondents agreed that the simplification of identifying who was responsible for the funeral was essential.

Linking the Funeral Payment directly to the deceased;

9.26 Some respondents talked about the possibility of linking the Funeral Payment to the deceased, rather than to the relatives or next of kin left behind. It was suggested that consideration should be given to the benefit status of the deceased, as opposed to the person arranging the funeral. This would reduce the need for intrusive questions about family relationships, simplify and speed up the process.

9.27 In addition, a few of these respondents felt that shifting entitlement of the Funeral Payment onto the deceased and away from relatives would make the identification process easier, quicker, and potentially make more people think about end of life finances ahead of time.

"Access to good insurance may be a better way of supporting those that cannot afford funeral costs - we aim to normalise this."
Volunteer Scotland

9.28 It was also suggested that a closer relationship between funeral directors and the Government would be beneficial. Funeral directors have direct contact with bereaved people and are skilled at sensitively establishing circumstances surrounding family relationships.

Eligibility requirements for the Funeral Payment

9.29 Respondents also talked about expanding or amending the eligibility criteria for the Funeral Payment to consider low income families, those on Working Tax Credit, Attendance Allowance, carers, care leavers and people with learning disabilities. They believed that Funeral Payments for people on low income benefits should be part of a wider devolved benefits strategy, which addresses the fact that funeral costs vary across local authorities. They felt that more could be done to establish a lower pricing structure for those on low incomes. Low cost loans were also mentioned as a possible alternative to the Funeral Payment.

"The Scottish Government should develop a system where the Social Fund Funeral Payment (SFFP) is raised to cover the cost of a basic funeral, and for funeral directors to provide a basic funeral with a clear, visible price."
The Church of Scotland

Sensitivity and respect

9.30 The complexities of some cases were discussed by some respondents. For example, if a child in care dies, funeral payments can only be made to the carer if the birth parent is in receipt of a qualifying benefit. This can be even more emotionally challenging for families with difficult or non-existent relationships.

"Each family situation is unique, and should be treated as such, with sensitivity and respect."
CELCIS

9.31 Respondents mentioned that selecting estranged family members to receive the Funeral Payment can make a difficult time even more challenging. Some of these respondents felt that decision makers should consider the difficulties bereavements have on already fragile relationships, and approach Funeral Payment in a person-centred way.

"Decision makers should consider not only their relationship with the deceased but also their relationship with the applicant / persons organising the funeral."
Quaker Social Action

Funeral Payment Fraud

9.32 A few respondents commented on fraudulent claims in relation to Funeral Payments. While a few believed fraudulent claims were not common or cause for concern, others suggested the system should be monitored effectively.

"Is there much evidence of Funeral Fraud to justify the concerns around who is the most appropriate person?"
Grampian Housing Association

"Perhaps following the principles of the Death Certification Review Service, applications could be processed more quickly but randomly called in for scrutiny."
National Association of Funeral Directors

Information and advice

9.33 A few respondents felt that more information and advice could be provided by the Scottish Government and partner agencies about the Funeral Payment. They said that clear guidelines should be issued to the public by decision makers, around who is and is not eligible for the Funeral Payment. Some felt that face to face, telephone and online information and advice should be available.

"We feel that a clearer explanation of what would be covered and who was eligible to claim should be available."
Fife Federation of Tenants and Residents Associations ( FFOTRA)

Question - In terms of the Scottish Funeral Payment, are there any qualifying benefits ( e.g. Pension Credit) that you would add to or take away from the current qualifying benefit list? Please explain your answer.

Table 9.3 In terms of the Scottish Funeral Payment, are there any qualifying benefits ( e.g. Pension Credit) that you would add to or take away from the current qualifying benefit list?
	Yes		No
Respondent group	Number	%	Number	%	Total
Individuals	29	49%	30	51%	59
Organisations	34	64%	19	36%	53
All respondents answering	63	56%	49	44%	112

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

9.34 A total of 112 respondents answered the closed part of this question. Views were fairly mixed, with 56% of respondents agreeing and 44% disagreeing that there were qualifying benefits that they would add to or take away from the current qualifying benefit list. Organisations were slightly more likely than individuals to answer 'yes'.

9.35 Further comments were provided by 96 respondents (39 individuals and 57 organisations).

No changes to qualifying benefits required

9.36 Some respondents were happy with the qualifying benefits included in the consultation document. It was suggested that people might be encouraged to take out insurance or savings plans, to prepare for such events, rather than increase the number of people entitled to assistance.

Additional qualifying benefits for the Scottish Funeral Payment

9.37 Many respondents suggested additional qualifying benefits in relation to the Scottish Funeral Payment. These included:

• Council Tax Reduction;
• Carer's Allowance / Scottish Carer's Benefit;
• Working Tax Credit;
• Disability Living Allowance / Personal Independence Payment
• Contribution based benefits, such as Employment and Support Allowance;
• Any means-tested benefit, Tax Credit or Disability Allowance;
• State pension;
• Child Tax Credit; and
• Attendance Allowance.

"These [contributory based] benefits are no longer paid at higher rates than their income based counter parts therefore there should be no exclusions because of this."
NHS Lanarkshire

Qualifying benefits that should be excluded from the Scottish Funeral Payment

9.38 Only a few respondents said that certain qualifying benefits should be excluded from the Scottish Funeral Payment. A few respondents felt that only those in receipt of Pension Credit should qualify for the Funeral Payment, as this would simplify the system.

9.39 A few other respondents suggested that some people claiming Pension Credit should not be eligible for the Funeral Payment, if they have a high weekly applicable amount or significant savings.

9.40 A few also suggested that the various elements of Universal Credit should be reviewed as all may not be relevant to the Funeral Payment. A few said that non-income based benefits should be excluded.

"It may be necessary to review eligibility of Universal Credit claimants as this can cover a wide range of circumstances."
Argyll and Bute Council

9.41 A few respondents suggested that means-testing should be introduced in some circumstances.

Special considerations

9.42 A few respondents talked about special circumstances that they felt the Scottish Government should take into consideration when administering the Funeral Payment. They said that decision makers in the new Scottish social security agency could have recourse to 'exceptional circumstances' regulations, to ensure that some cases which risk falling through the net are considered. For example, a few felt that some people are ineligible for the Funeral Payment even though they are experiencing severe financial hardship. Some of these circumstances included:

• a special funeral grant for a stillborn baby;
• discretion to make payments to people who are marginally above the threshold for benefits, with no means to pay funeral costs;
• consideration of how to support those eligible for certain benefits, but who are not receiving them;
• those in full time education; and
• single people with no immediate family or relatives.

"Funeral Payment should also be available to households who are not in receipt of any of the listed benefits but who have an income below an established threshold."
CPAG Scotland

9.43 A few respondents stated that the Scottish Funeral Payment must be a flexible benefit, assessed on a case-by-case basis.

"Nothing should be ruled out or ruled in."
Scottish Working Group on Funeral Poverty

Targeted support

9.44 A few respondents felt that the Funeral Payment should be reserved for those most in need of support, including those receiving Pension Credits. They said that the Scottish Government must ensure that it reaches the right people. Such respondents talked about funeral poverty, and the negative impact that it could have on those bereaved. Often, they felt that the measures outlined in the consultation would go some way to addressing this, although there was concern that the proposals would not provide enough help for families on low incomes. The development of an automatic base payment for all older people, which would increase with age, was suggested.

Application window and process

9.45 The Scottish Government set out its proposals for the application window and process in Part 2 of the consultation document.

Question - Is the three month application window for a Funeral Payment sufficient time for claimants to apply? If no, please explain your answer and suggest an alternative length of time in which a claim should be made.

Table 9.4 Is the three month application window for a Funeral Payment sufficient time for claimants to apply?
	Yes		No
Respondent group	Number	%	Number	%	Total
Individuals	42	65%	23	35%	65
Organisations	34	54%	29	46%	63
All respondents answering	76	59%	52	41%	128

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

9.46 A total of 128 respondents answered this question. Views were fairly mixed. Most respondents (59%) thought that the three month application window for a claimant to apply was sufficient time, but a significant minority (41%) disagreed.

9.47 A total of 72 respondents provided further comments (49 organisations and 23 individuals).

9.48 In addition to the time frame for Funeral Payments, respondents also discussed:

• the emotional impact of bereavement and ill health;
• the application process, delays and other practicalities; and
• the impact of qualifying benefits and other insurance.

Suggested timeframes

9.49 While many supported the current three month timeframe, a few respondents suggested that extensions and appeals may be required to accommodate the needs of people in exceptional circumstances. This could include illness or injury, people with learning and physical disabilities, situations where people were unaware of their entitlement or had been given incorrect information about it, or where a death was sudden or unexpected (including the death of a child). It was suggested that funeral directors might play an important role in assessing special circumstances, and this should be built into the process.

9.50 Many respondents suggested alternative timeframes for the Funeral Payment application window and process:

• Many indicated that the timeframe should be extended to 6 months. A minority of these respondents said that this should only be the case under special circumstances.
• A few respondents suggested a 9 to 13 month window.

9.51 A few respondents felt that extending the window beyond three months would increase pressure on funeral services, who may become reluctant to deal with people receiving Funeral Payments in the future.

Consideration of the emotional impact of bereavement and ill health

9.52 Some respondents said that the three month application window was too narrow, particularly for claimants who are ill, have physical and mental disabilities, or who are struggling with the emotional challenges of a bereavement. Such respondents said that certain individuals may be emotionally fragile, and not capable of making decisions or dealing with practical issues at such a stressful time. Respondents added that this can be a difficult time for people with learning disabilities, especially if it relates to the death of a carer.

"A longer window of application would provide some leeway for those applicants with significant changes to their life or who are going through difficult grieving processes.
Citizens Advice Scotland

9.53 These respondents said that while most applicants will apply within a short time period, a longer window is required to ensure that all eligible individuals can apply. It was suggested that a longer window would help those who are struggling with on-going funeral debts. A few respondents supported a system in which benefit claims could be fast-tracked, prior to the death of a person with a terminal illness.

Consideration of the application process, delays and other practicalities

9.54 Many respondents indicated that a three month window to apply for the Funeral Payment was not sufficient for more specific practical reasons. These reasons included:

• people who are eligible being unaware of the benefit;
• allowing for retrospective applications under certain circumstances;
• claimants being given the wrong information about the payment;
• people who require pre-application advice and support;
• giving claimants time to access funds and clear funeral debts;
• providing more time to deal with necessary application forms and paperwork;
• allowing more time to deal with the many practicalities of arranging a funeral, including dealing with the deceased's estate, approaching a funeral director, organising the burial or cremation, transport, ceremony or wake;
• accounting for delays in the system including the assessment process and administrative errors, such as lost application forms; and
• giving people time to appeal a rejected application.

"The Scottish system should seek to ensure that all who are eligible make a claim and any time limit acts as a barrier to this."
Scottish Campaign on Welfare Reform

"There is a great deal to do, in a short period of time."
Scottish Out of School Care Network

9.55 Some of these respondents felt that the process would be much more supportive and effective, if extended beyond 3 months.

"We do not feel that increasing the time period to six or twelve months would bring any significant issues given the limited scope of the scheme."
ENABLE Scotland

9.56 A few of these respondents believed that the time limit should be flexible and assessed on a case-by-case basis.

Impact of qualifying benefits and other insurance

9.57 Closely related to the above, a few respondents talked about the impact of qualifying benefits on claiming the Funeral Payment. These respondents highlighted that Funeral Payments can only be awarded when a qualifying benefit is in place. This means that if there is a stoppage in or dispute about a qualifying benefit, most commonly a carer or disability benefit, then this individual cannot apply. Respondents also talked about the difficulty of sorting out relevant insurance claims, relevant to the death, within a three month application window.

"As the run on of Carer's Allowance following the death of a cared for person is shorter than the application window for a Funeral Payment, it is possible for a carer to lose the ability to claim a Funeral Payment following the end of the run on of income support."
Carers Trust Scotland

Simplification

9.58 The Scottish Government set out its proposals for simplification in Part 2 of the consultation document.

Question - What are your views on the options for speeding up and simplifying the payment?

9.59 A total of 116 respondents answered this question. 67 of these respondents were organisations, and 49 were individuals.

9.60 Some respondents agreed with proposals outlined in the consultation. These respondents felt that the ideas were good, and a step in the right direction. They said that the proposals should simplify the process of arranging and financing a funeral, and seemed workable and sensible. Others felt that the proposals would make a difficult process more considerate and compassionate.

9.61 The main themes emerging were:

• application and decision-making process;
• checking eligibility;
• the payment process;
• fast tracked payments for people with terminal illnesses; and
• family relationships.

Application and decision-making process

9.62 A large number of respondents discussed the application and decision making process. Some of these respondents wanted to see the time for decisions reduced to 10 days or less following an application, so that a decision is made before a funeral takes place.

"Funeral Directors need to know at the time of arranging the funeral if the funeral can and will be paid for. DWP should make a quick decision and pay the funeral director if approved."
Mark Shaw Funeral Services Ltd

9.63 A few respondents felt that allowing decisions in principle would give families and funeral directors the confidence to proceed with funeral arrangements immediately. These respondents liked the idea of an immediate decision in principle for claimants, combined with up front interim payments, as this would help to ensure that individuals on low income would not get into debt.

"We support the proposal to process applications within ten working days of receipt and make payments as soon as practicable thereafter, especially if this reduces the need for funeral directors to take a deposit from the bereaved."
Parkhead Citizens Advice Bureau

9.64 Some respondents suggested that local authorities should play a greater role in speeding up the application and decision making process. Others talked about involving funeral directors in making payment claims on behalf of families, which they felt would streamline the process.

9.65 In contrast, a few respondents felt that funeral directors could complicate and lengthen the payment process. It was suggested that people are often encouraged to commit to a funeral they could not afford, prior to any payment being agreed or made. It was also suggested that funeral costs could be standardised across local authority areas.

"The Church of Scotland is a member of the Funeral Poverty Alliance which has developed the Fair Funeral Scheme. This calls on Funeral Directors to sign a pledge to recognise that funerals can be expensive, and people struggle with the cost."
The Church of Scotland

Checking eligibility

9.66 Some respondents talked about the need for clearer guidelines around eligibility. They felt that qualification criteria regarding the applicant and the deceased should be easier to understand and that signposting should be improved so that claimants know where to go for help and advice. Respondents said that they would like to see more information shared between statutory agencies rather than requiring applicants to gather it themselves, which they felt would speed up the process.

9.67 Some respondents talked about the proposal to develop an online eligibility checker, and most of these respondents welcomed this. This would enable early checking of eligibility for claimants, allowing for better funeral planning.

9.68 A few respondents also suggested a telephone eligibility service. This would enable people to more quickly check if they are eligible for the benefit, and how much they would be likely to receive. This would give the bereaved and funeral directors the assurance to proceed.

"Our advisers are able to provide this service to people by asking a series of questions and because of strong knowledge of the eligibility criteria their accuracy rate is around 100%."
Quaker Social Action

Payment process

9.69 Some respondents talked about the possibility of introducing interim or advance payments, or a deposit scheme to help in the early stages with funeral costs. Most funeral directors will not proceed without a deposit. A few respondents talked about developing a low-cost funeral loan option, for those who do not qualify for the Funeral Payment.

"There is already provision for advance payments in other benefits therefore this could be easily implemented."
NHS Lanarkshire

9.70 Some respondents supported a fixed payment amount to contribute to funeral expenses. It was suggested that this would give some certainty to the bereaved at a difficult time. It could also provide clarity to families over which costs the payment would cover (and which it would not). Others said that the fixed payment would make the process more predictable and less administratively onerous. It was felt that it would allow funeral directors to proceed more quickly with the funeral arrangements.

9.71 Some respondents discussed the option of funeral directors being paid a deposit, interim payment or fixed cost directly. A few respondents said that when full costs are established, families could be advised whether they are liable for reimbursement. These respondents said that by working directly with funeral directors, the process could be significantly quicker.

"This should result in an easier and quicker process for applicants."
Humanist Society Scotland

9.72 A few respondents were unsure about or disagreed with the idea of a fixed payment. A few thought that this might take choice and flexibility away from families, in arranging the type of funeral they want. These respondents also highlighted the variation in costs across funeral service providers, and questioned whether the fixed payment amount would be a good idea, or lead to inequity across different areas. A few wanted clarification over what the fixed amount would cover.

"No, I think you need to pay the proper allowable costs; an estimated amount could leave people out of pocket."
Individual

Fast tracked payment for people with terminal illnesses

9.73 A few respondents believed that the Funeral Payment should be fast tracked for people with terminal illnesses. This would allow them to be involved in the planning of their own funeral should they wish, and make the process less stressful for family and friends. These respondents agreed with proposals that the DWP DS1500 form could be used to fast track the benefit under such circumstance, allowing an application to be made, and decision in principle received, before they die.

"This would be very comforting for the person who is dying to know that their family is going to be free from crippling financial burdens following their death."
Individual

9.74 A few disagreed with this idea. They felt that it was disrespectful to the person with a terminal illness.

Family relationships

9.75 A few respondents said that there was a need to remove the requirement to check family relationships before the funeral benefit is awarded. It was suggested that this was the biggest cause for delay in the system. Such respondents supported the Scottish Government's proposal that contributions from families and friends are not deducted, as often these relationships involved estranged individuals. This could make the process more intrusive and distressing for the bereaved. They felt that removing this requirement would help simplify the application process.

"I think it would be much simpler and better to base it on the deceased benefits- financial estate."
Western Isles Carers, Users & Supporters Network ( WICUSN)

Deductions

9.76 The Scottish Government sets out its proposals for deductions in Part 2 of the consultation document.

Question - The other funds which are deducted from the DWP funeral payment are listed below. What sorts of funds do you think it is appropriate to deduct from a Scottish FP?

Table 9.5 Which sorts of funds do you think it is appropriate to deduct from a Scottish Funeral Payment?
Possible deductions (ordered by level of support)	% of respondents
	Yes	No
Funeral plan / insurance policy	93	7
Money from a burial club	84	16
Funds in the deceased's bank account	76	24
Money from an occupational pension scheme	66	34
Contributions from charities / employers	64	36

9.77 A total of 134 respondents (59 organisations and 75 individuals) answered this closed question. Five suggestions were listed, and respondents were asked to decide if each should, or should not, be deducted from the DWP funeral payments.

9.78 There was overall support for the deductions listed, with more respondents saying 'yes' than 'no' for all of them. There was most support for deductions associated with funeral plans or insurance policies, and money from burial clubs.

9.79 At the end of the question, respondents were offered the chance to comment on any other funds that would be appropriate to deduct. 54 people provided a response. Substantive comments are discussed under the next question which asked the same thing.

Question - Are there any other funds that you think are appropriate to deduct?

9.80 A total of 66 respondents answered this open question (37 organisations and 29 individuals).

9.81 The main themes emerging were:

• no other deductions would be appropriate;
• use of contributions from the deceased's estate;
• other deductible funds; and
• funeral savings plans.

No other deductions appropriate

9.82 Some respondents said that they did not believe that there were any other funds that would be appropriate to deduct from the Scottish Funeral Payment. Respondents suggested that simplification of the process was of utmost importance, and deductions sent out a confused message to claimants. Other respondents said that if sufficient funds were made available through the Scottish Funeral Payment, then deductions would not be an issue.

Contributions from the deceased's estate

9.83 Some respondents reiterated that contributions from the deceased's estate should help pay for the funeral costs, and would therefore be appropriate to deduct from the Funeral Payment. This could include funeral insurance, stocks and shares, savings or investments, or a burial plan. A few suggested it was only appropriate to deduct bank funds over a set amount.

"Any money, including that paid out under insurance provisions on their death, should be deducted from awards made to applicants."
Citizens Advice Scotland

"It is appropriate to deduct income or savings that belong to the deceased as well as any pre-paid arrangements that have been made."
ENABLE Scotland

Other deductible funds

9.84 A few respondents mentioned other funds which could be deducted from the Funeral Payment. An example given was of a care home building up a small fund for a resident, through payments from relatives, was provided. This was contributed to the cost of the deceased's funeral. Other potential deductible funds included:

• benefits, rent, Council Tax or utilities overpayments; and
• proceeds of crime.

9.85 Some respondents however, felt that it was not appropriate to deduct contributions from pension funds, family, friends or other charitable grants. It was highlighted that currently the DWP makes deductions for money raised to help pay for a funeral deposit from family, friends or other initiatives including 'crowdfunding'. Respondents were concerned that in some instances this led to the accumulation of funeral debt. Sometimes, small charitable grants, for example, from military service charities, helped contribute to initial costs. They did not think that it was fair to include these donations in the calculation of the Scottish Funeral benefit, because the basic benefit is not enough to cover the full costs of the funeral.

"The average Funeral Payment covers only 37% of the cost of a basic funeral."
Inverclyde Council / HSCP

Funeral savings plans

9.86 A few respondents talked about the need to promote plans for saving for funeral costs. They felt that this could be promoted through local authorities and relevant third sector agencies. This would reduce the need for deductions, and therefore simplify the process further.

Improving take up

9.87 The Scottish Government set out its proposals for improving take up in Part 2 of the consultation document.

Question - Which services should promote awareness of the Funeral Payment to ensure that claimants know about it at the relevant time?

9.88 In total, 121 respondents answered this question (51 individuals, 70 organisations). The most commonly mentioned services were:

• Funeral directors / funeral homes;
• Registrars;
• NHS / health professionals;
• Hospitals / health centres;
• Hospice / palliative care services;
• GPs;
• Advice services / third sector/community groups;
• Bereavement support services;
• Local authorities;
• Social care / social work services; and
• Scottish Government / DWP / Scottish social security agency.

9.89 A full list of services mentioned by respondents is included in Appendix 3.

Question - Are there any other points that you would like to raise in connection with the new Scottish Funeral Payment?

9.90 A total of 84 respondents answered this question. 51 of these were organisations, and 33 were individuals.

9.91 The main themes emerging were:

• Recognition of funeral poverty - The need to develop a Scottish Funeral Payment that would help reduce or eliminate funeral poverty for low income families and individuals.
• Controlling funeral costs - Most respondents wanted to see funeral costs decreased or capped, and standardised across local authorities and funeral directors
• Level of Funeral Payment - Payments should increase in line with costs and inflation and felt that funeral directors should commit to offering affordable, basic funeral packages.
• Religious, cultural and equality considerations - Consideration should be given and any extra costs should be taken into account.
• Funeral savings plans - People should be encouraged to save for funeral payments in advance.
• Awareness raising - The Scottish Government and local authorities should run a promotional campaign to raise public awareness.

"Full expenses for a dignified simple funeral should be provided recognising that bereavement is frequently a trigger for debt."
Rights Advice Scotland

"Expenditure on SFFP grants has increased only 4.5% since 1988. This represents a massive real-term decrease in expenditure."
Quaker Social Action

"People in our society no longer make provision for their future funeral as a matter of course in the same way that older generations did."
Scottish Borders Council

"There may be ways to improve information provided about funerals and funeral payments, to ensure people are able to access what they are entitled to and are better prepared."
Scottish Campaign on Welfare Reform

Other factors for consideration

9.92 Many additional points were made by some respondents that were highlighted in previous questions of the consultation. These included:

• awarding an interim payment or deposit to address the issue of up front funeral payment costs;
• providing ring fenced funding to be distributed through, for example, housing associations;
• direct payments to funeral service providers;
• not deducting contributions from family, friends, charities or employers from the Funeral Payment;
• better regulation and possible licensing of funeral directors - transparency of costs;
• considering low interest loans to cover funeral payments;
• designing a person-centred system, aided by better joined up working between services and agencies;
• a National Insurance contribution scheme to fund funeral payments; and
• including a universal basic funeral package into the free treatment we receive such as giving birth and normal health care.