Carer Benefits Advisory Group minutes: February 2023

Attendees and apologies

Present

• Ed Pybus, CPAG (Child Poverty Action Group)
• Evelyn Bowes, Georgia O’Brien, Richard Keatinge, David Anderson, Scottish Government (SSAFE)
•  Jill Wood, Engender
• Michelle Gallacher, Social Security Scotland (Agency)
• Roisin Connolly, Connecting Carers
• Stephen McCabe, Scottish Government Social Security Programme
• Suzanne Munday, MECOPP (Minority Ethnic Carers of Older People Project)
• Dawn Kane, Jane Sterry, Kamay Whytock, Kate Thomson-McDermott, Lynn Shaw, Robin Briggs, Sohel Ahmed (Chair), Victoria Boal (secretariat), Scottish Government Carer Benefits Policy

Apologies:

• Angela Toal, CPAG (Child Poverty Action Group)
• Fiona Collie, Carers Scotland
• Jennifer Rezendes, Social Work Scotland
• John Cunningham, COSLA (Convention of Scottish Local Authorities)
• Paul Traynor, Carers Trust
• Stephanie Millar, Citizens Advice Scotland
• Sharon McGuire, Scottish Government (Carers Policy) 

Items and actions

Member updates 

The new name of Scottish Carer’s Assistance was confirmed to be Carer Support Payment, as previously announced by the Minister.

The chair asked if there were any updates from group members, or any concerns they wished to raise, of which there were none.

BAME report on Carers – Suzanne Munday (MECOPP)

Suzanne gave a presentation on behalf of MECOPP and the work they do to support some of the most excluded and marginalised minority ethnic carers and service users. She provided in-depth overview of how they provide advice, information and advocacy/case work support in the language spoken by the individual.

Members queried as to whether MECOPP provides support around Social Security Scotland entitlement and income maximisation, to which it was confirmed that this is a huge part of their work. They also work to support carers in applying for devolved benefits, and any reviews or appeals that are required as a result of the application processes.

Members expressed how research conducted alongside carers who have English as a second language could face difficulties accessing information.

It was further highlighted that carers whose first language isn’t English may prefer face to face support for receiving information regarding benefit and support entitlement. This allows them to ask questions, reflect on personal experiences in their first language. It was queried how MECOPP arranges the workshops they conduct for carers. Suzanne acknowledged that this was difficult to do throughout the pandemic, as digital exclusion can be prevalent in minority communities. These workshops to support clients and carers tend to be jointly established through MECOPP’s networks. Suzanne offered to share her contact details with the Lived Experience Panel Team, as well as other members of CBAG.

The major recommendation the report laid out to counter this was to increase financial support for carers by increasing the amount of Carer’s Allowance. Suzanne recognised that with the introduction of Carer’s Allowance Supplement, the Scottish Government has offered more in terms of support than their Westminster counterpart. 

The report also addressed how the devolved systems can also cause issues, as clients can find it difficult to understand the differences between Social Security Scotland and Department for Work and Pensions (DWP) systems. 

Moreover, officials confirmed that there is a benefit take-up strategy in place to increase uptake, with a focus on areas – such as minority communities – where uptake is disproportionately low.

Officials highlighted that some minority groups have mentioned a stigma surrounding asking for support; and queried how the Scottish Government can work on increasing uptake for these groups in spite of any stigma. It was recognised that whilst lots of clients have reported positive experiences within Social Security Scotland (the Agency), there can still be a stigma in applying. This is where the role of a community intermediary would be useful, to support those in the community to apply and link them with  supporting organisations and practitioners.

Members raised the issue that many benefits or support avenues require photographic ID to apply, which can exclude eligible clients. It was questioned whether the Agency monitors how many people are being disadvantaged by not having any photographic ID.

Suzanne concluded with the offer that MECOPP could provide training and awareness for decisions makers to ensure everyone has insight into traveller communities.

Actions

• officials to share Suzanne’s email with the group if they would like to discuss further by the next meeting
• officials to ask colleagues in Social Security Scotland if they are monitoring when photo evidence is required, and if there is any evidence that it is affecting certain communities more by the next meeting
• officials to share Benefit Take-Up Strategy with the group and email of officials who lead this work by the next meeting

Update on Carer Support Payment Regulations 

Officials provided an update on Carer Support Payment which is launching this year, acknowledging the Scottish Government’s appreciation for the input from Group members; including the research that went into approving the name Carer Support Payment.

Members queried what the justification was for the proposed past presence test, as someone from abroad arriving to the UK could potentially have their access to benefits delayed. Officials noted that the overall residency approach for Scottish benefits has been considered in detail and the past presence test proposed for carer benefits is in line with that for disability benefits. The test would also be dis-applied in the same circumstances as it would be for Scottish disability benefits, including in cases of terminal illness. 

The proposed abatement process for legacy benefits was also noted; with officials looking to put provision in regulations to work with the DWP to prevent overpayments of legacy benefits when someone applies for Carer Support Payment. This would mirror closely current processes already in place for Carer’s Allowance

Officials also updated the intention not to provide for advanced applications during the pilot due to the complexity involved. The position for national was being considered further.

Officials also confirmed the intention to have payments made every four weeks in arrears, which is the standard payment cycle for Social Security Scotland. Weekly in advance payments would still be available to those who are terminally ill, those who are caring for people who are terminally ill, and for those transferring over from Carer’s Allowance on that payment cycle. Making payments in arrears rather than in advance reduces the risks of overpayments as it provides more time for changes in circumstances to be processed. 

It was also discussed that regulations regarding earnings will mirror Carer’s Allowance on launch, due to the Scottish Government’s commitment to avoid treating carers differently. While officials have looked at a range of ways to simplify or streamline processes, in practice there is not much scope to make these any simpler and effectively deliver on the policy. The approach to earnings and the earnings threshold is one that will be kept under review given the innate complexity of the current processes.

Officials are aiming to have draft regulations ready to present to the Scottish Commission on Social Security in the next few weeks – setting out how the benefit will work on launch and in provisional case transfers.

Future changes

In line with Scottish Government policy to increase benefit take-up, officials are working with the Social Security Scotland and Carer Policy colleagues to improve how clients are signposted to wider support. This includes developing signposting text for client letters and notifications, as well as improving training for Social Security Scotland staff on Carer Benefits so that they are aware of the issues carers face.

Members queried that as research shows that referral networks are more effective than signposting, whether the Scottish Government considered referral pathways to ensure that carers are referred to the relevant support, rather than signposted. There was also a concern that Social Security Scotland were reluctant to provide advice on reserved benefits. Officials responded that it is not for client advisors to provide advice to individuals on their specific circumstances. The signposting work was looking to ensure it was clear where such advise could be found. There are also ongoing discussions to look at referral process as part of continuous improvement, which officials would look to bring back to the group in due course.

In the consultation, there were positive responses to Short-Term Assistance, which officials are now looking to introduce after case transfer is complete. It hasn’t yet been agreed with the DWP as to how this will interact with reserved benefits – with concerns that it would not properly benefit carers if this ultimately reduced the amount of support carers got elsewhere. Introducing this after case transfer is complete also means that there will be no discrepancy between how carers on Carer Support Payment and those currently on Carer’s Allowance are treated. As previously discussed with the group this would likely be introduced at the same time as the Carer’s Additional Person Payment once case transfer is complete, due to the complexity of the interactions with the DWP systems. 

The consultation also highlighted that carers felt that the amount of Carer Support Payment could be increased, which has been noted and will be considered further in the context of the current fiscal circumstances.

The last significant issue from the consultation responses discussed was the reduction of education restrictions.  Officials are currently considering where and how to make these changes and are aware members have concerns about the details of this. The policy intent is to allow those studying less than 21 hours, those aged 20 or over studying 21 hours or more either advanced or non-advanced educations, and those carers aged 16-19 in full time advanced education to access Carer Support Payment. Those aged 16-19 studying non-advanced education courses would not be entitled to Carer Support Payment. They would however continue to be supported through reserved benefits such as the child element of Universal Credit, and directly through the Education Maintenance Allowance. This is in line with the policy design for Young Carer Grant where we week to ensure that young people are not incentivised to take on full time, substantive caring roles at a time when they would otherwise be focused on completing secondary school level education. Officials are continuing to consider the detail of this proposal further and an update will be provided on final policy detail. 

Concerns were raised that Scottish Child Payment stops at sixteen, which could exclude 16-19 year old carers from accessing support. Officials confirmed that the intent of the policy is to avoid incentivising young people to take up full time caring roles. Around three hundred people under the age of eighteen are currently getting Carer’s Allowance. The DWP provides limited information on this issue. Officials will also ensure that the process is as straight forward as possible by putting in support and explanations on education/employment restrictions and making these readily available whether the carer is applying via phone, paper form or online. 

The recent letter from members regarding this is with the Minister, along with a draft proposed response. The points raised will continue to be considered when finalising the policy.

There were no further topics discussed under any other business.