Consultation on a Child Poverty Bill for Scotland: Analysis of Responses

Executive summary

This report presents the findings of an analysis of responses to the Scottish Government's consultation on a Child Poverty Bill for Scotland. The consultation ran from the 8 ^th August to the 30 ^th September, and explored respondents' views on the Scottish Government's proposals for a Child Poverty Bill, including:

• Enshrining in legislation an ambition to eradicate child poverty
• Reinstating statutory income-based targets to reduce the number of children living in poverty
• Placing a duty on Scottish Ministers to develop a Child Poverty Delivery Plan, and to report on annually on their progress towards delivering that plan.

A total of 116 responses were received. Thirty of these (26%) were from individuals, and the remaining 86 (74%) from stakeholder organisations.

An ambition to eradicate child poverty

Of the respondents who answered Question 1, most (94%) agreed with the Scottish Government including in statute an ambition to eradicate child poverty. A range of reasons for this support were outlined, including that the ambition would would be a 'clear and public expression' of the Scottish Government's commitment; provide focus or a 'clear direction of travel'; place child poverty 'high on the agenda'; and act as a driver of change. The need to consider Child Poverty legislation in the wider context of other policy and legislative developments, and to make sure it is aligned with existing structures, was highlighted.

Many also made the point that 'legislation alone won't eradicate poverty', underlining that the ambition must be backed up by 'actions', 'policies' and/or 'clear strategies'. Some reservations were noted, for example: the language for the proposed Bill should be stronger than 'an ambition', Scottish Government does not have all the relevant levers to address income inequality, and whether sufficient funding would be available to achieve the targets.

The income-based targets

The majority of respondents also agreed with the proposal to make the income targets statutory. Reasons given for agreement included that income is central to the experience of poverty, and that statutory targets would be helpful to focus efforts, are crucial in order to measure progress, and are in line with the United Nations Convention on the Rights of the Child ( UNCRC). Nevertheless, several responses underlined that poverty is not about income alone, mentioning other causes and outcomes of poverty such as: inequality, lack of opportunity, the cost of living, good parenting, access to childcare, education, housing, worklessness, and health and well-being. Some local partners felt more clarity is required over who will be responsible for collecting the data and reporting on targets, as well as who the income targets would be statutory for.

The majority of respondents agreed with the proposed income-based measures of poverty. Reasons provided for agreement were that using the existing measures meant that they are 'robust', 'well known' and 'widely understood', 'comprehensive and complementary' and allow comparison with past progress as well as international comparison. Additional aspects of poverty that several respondents thought were not sufficiently covered in the suggested measures focused on financial insecurity, depth/severity of poverty and taking into account the cost of living. A few respondents did not think that the persistent poverty targets were ambitious enough.

For the most part, there was agreement with the proposed levels for the targets to be set at. In general the proposed levels were seen as ambitious and challenging but realistic. In describing the levels as challenging, some respondents highlighted the background of UK welfare reforms, the Institute for Fiscal Studies ( IFS) projections that poverty will rise by 2020, and the challenging economic climate. A few respondents, based on this context, noted concerns that there is a risk the targets will not be achieved. Others underlined that 'significant political and economic effort' or 'more radical actions' would be required to meet these targets. However, most thought it was right that the targets were challenging. A few respondents raised the issue of the acceptability of leaving 5% of children in poverty, questioning whether this met the goal of 'eradication' or underlining that these targets should be seen as the starting point in eradicating child poverty. Some respondents wanted more information on the evidence base used to determine the target levels.

Most respondents agreed with setting the targets on an After Housing Costs ( AHC) basis, highlighting that "housing costs are a significant factor in poverty" and that measuring poverty AHC provides a better indication of the resources available to households. Several respondents underlined the importance of continuing to report on both Before Housing Costs ( BHC) and AHC, noting that gathering information on both allows poverty to be better understood. A few respondents highlighted that the BHC measure allows national and international comparisons, which are important. A few respondents also suggested measuring poverty after other costs such as energy, transport and childcare.

Most respondents agreed that the 2030 date for the targets to be achieved by was appropriate suggesting that this date would be realistic, allow for long-term planning, and aligns with other action plans, particularly the Fairer Scotland Action Plan. A few noted disappointment that the Race Equality Framework for Scotland 2016-2030 was not mentioned specifically in the consultation document. A few suggested they would like to see evidence of why this date was chosen as appropriate. A minority of respondents felt that the 2030 date was not ambitious enough and the targets should be achieved in a shorter timeframe. Others drew attention to the children who would be growing up in poverty during this timeframe. Many underlined the need to set interim targets or milestones to maintain momentum, assess progress, and make sure we are "making a difference to families in poverty now".

The role of the Ministerial Advisory Group on Child Poverty

A range of suggestions were made for developing the role of the Ministerial Advisory Group. Key areas where the Ministerial Advisory Group was seen as having a role were: in advising on priorities and action; making links across different sectors and levels; independent scrutiny and monitoring; and disseminating good practice. Additionally, a few respondents felt that there should also be an independent body or commission established to provide oversight and scrutiny of the Scottish Government and its parters' progress towards the targets. Some respondents noted that there was a lack of information available about the role and activities of the Ministerial Advisory Group, and suggested that the role of the group should be higher profile and its visibility should be increased.

Several also thought that, with the changing legislative situation, the remit of the Ministerial Advisory Group and its representation should be revisited. A wide range of suggestions were made for representation on the Ministerial Advisory Group. In particular, many respondents stressed the importance of engaging with and including the voices of families and young people who have experience of living in poverty, and saw the Ministerial Advisory Group as having a role in ensuring their views are taken into account.

Links between the national strategy and local implementation

In considering how links between the national strategy and local implementation could be improved, many respondents noted the importance of taking a strategic approach across stakeholders and of partnership working, and welcomed the Scottish Government's focus on this. Several respondents highlighted that it would be important to clarify roles and responsibilities for all partners. A need for clarity over expectations around whether local authorities would produce and report on local strategies was also identified. In general, those who discussed requiring local targets and reporting felt this would be appropriate, but that reporting ought to be proportionate and streamlined with existing duties, targets and reporting requirements so as not to place too great a burden on local authorities and Community Planning Partnerships. Some respondents suggested that a duty should be placed on local authorities and/or Community Planning Partnerships to reduce child poverty locally and report on progress. Roles identified for the Scottish Government included providing advice on prioritising different national initiatives and supporting local partners in identifying and sharing effective approaches to tackling poverty.

The Child Poverty Delivery Plan

In general, respondents agreed that the proposal to produce a Child Poverty Delivery plan every five years and to report on the plan annually would be appropriate. Several responses highlighted that the five year plan was a 'realistic timeframe' and would provide a strategic focus and allow a focus on longer-term outcomes; but also that it is important to assess progress regularly to 'provide accountability and transparency', which the annual reporting would allow. A few mentioned that aligning the delivery plan with parliamentary terms would be helpful, but also that the first delivery plan should be produced as soon as practicable within the current parliament. Others highlighted the importance of being able to revise and review delivery plans at regular intervals in order to take account of changing circumstances.

Some respondents noted that thought would need to be given to what would be reported annually, as many indicators would not be expected to change in this timeframe. Several respondents underlined the importance of taking into account local authority planning structures and reporting timescales, including Children's Services planning and Local Outcome Improvement Plans. A few suggested that the annual reports should be presented to Parliament and scrutinised by Committee. A minority of respondents questioned whether five-yearly delivery plans would be the most appropriate timeframe. Some individual respondents felt five years was too long. A few organisational responses suggested a four-yearly timeframe in order to allow three delivery plans to be produced within the timeframe. Others suggested a three-yearly timeframe so as to be consistent with other local reporting structures, such as Children's Planning cycles. The importance of adequately resourcing the delivery plan and being clear on actions and responsibilities was again highlighted by some in reponses to this question.

The Child Poverty Measurement Framework

A number of respondents stated their support for the child poverty measurement framework. Some respondents mentioned the importance of linking the framework with existing Scottish Government policies, as well as embedding children's rights through the United Nations Convention on the Rights of the Child. It was also felt that certain existing data sources, and sets of indicators could feed into the future development of the measurement framework.

Some respondents called for a greater emphasis on income and the 'Pockets' indicators. However, others suggested the framework contain fewer indicators and focus on indicators which are already incorporated within existing frameworks in order to reduce the burden of data collection. A recurring critique of the existing indicators was that the link to eradicating child poverty was not always clear. A preference for indicators linked to the four income-based targets was also expressed. Suggestions for amending specific indicators focussed on the 'Prospects' indicators on attachment, nutrition, apprenticeships and smoking. A number of respondents commented that those who share certain protected characteristics are more likely to experience poverty, and this should be reflected in the framework. Disaggregating data by equality characteristic where possible was suggested. The differing experience of poverty in rural compared to urban locations was also highlighted.

There were a number of suggestions for additional indicators under each of the three P's, 'Pockets, 'Prospects' and 'Places', with a number of respondents placing an emphasis on 'Pockets'. The most commonly suggested 'Pockets' indicators related to benefits, with indicators relating to parental employment, debt, childcare and the "poverty premium" also frequently suggested. For 'Prospects', a range of additional health indicators were suggested. Data relating to child protection and looked after children, educational attainment, and food poverty and household food insecurity were also mentioned. Indicators around fuel poverty were the most commonly suggested under 'Places', followed by access to, and satisfaction with hobbies/culture/sport/leisure and play facilities. Indicators around housing quality were also suggested.