Consultation on regulations and statutory guidance under the Welfare Funds (Scotland) Act 2015: Analysis of Responses

11 COMMENTS ON THE APPLICATION FORM

11.1 During the passage of the Welfare Funds (Scotland) Act 2015 through Parliament, comments were made about the structure, length, and content of the (interim) application form. The final three questions of the consultation (Questions 20-22) asked about the application form for the permanent SWF.

11.2 The interim SWF has a single application form for both grants (CG and CCG), and respondents were asked whether this should continue to be the case. Respondents were also asked whether they had suggestions for rationalising and / or improving the application form in preparation for the introduction of the permanent SWF.

Question 20: Should the application form for the permanent SWF be a combined CG and CCG application form or two separate application forms?

Please explain your answer.

Question 21: What information is collected on the application form for the interim SWF that you do not think is needed to assess the application?

Question 22: How can the application form for the interim SWF be improved for the permanent SWF?

A combined CG and CCG application form or two separate application forms? (Q20)

11.3 Table 11.1 below shows that 59% of respondents favoured a combined CG and CCG application form whereas 41% favoured separate forms. Local authorities were more likely than other groups to favour a combined. By contrast, housing organisations were the least likely to favour a combined form.

Table 11.1: Should the application form for the permanent SWF be a combined CG and CCG form or two separate forms?

	A combined CG and CCG application form		2 separate application forms		Total
Local government	13	72%	5	28%	18	100%
Third sector / equality organisations	7	54%	6	46%	13	100%
Housing organisations	2	29%	5	71%	7	100%
Other organisational respondents	3	60%	2	40%	5	100%
Individuals	5	63%	3	38%	8	100%
Total	30	59%	21	41%	51	100%

11.4 Altogether 53 respondents (46 organisations and 7 individuals) made comments at Question 20. A small proportion of these comments were suggestions for improving the application form and have been addressed in the analysis of Question 22 below.

Arguments in favour of a combined CG and CCG application form

11.5 There were four main arguments made in favour of a combined form. The first two of these were often linked, with respondents presenting both elements as part of a single rationale. Moreover, the arguments were often articulated as arguments against separate forms (rather than as positive arguments in favour of a combined form).

11.6 The first argument related to the perspective of a person applying for a grant. The point was made repeatedly that applicants often did not understand the differences between the two grants and would therefore not know which application form to complete if there were two separate forms. From the perspective of the applicant, a combined form removed any confusion, and removed the possibility of time delays which would result if an incorrect form was submitted. Moreover, in a substantial number of cases, an individual applicant applies simultaneously for both a CG and a CCG. Thus, having a combined form in these cases was preferable.

11.7 The second argument related to the perspective of the staff who were involved in providing advice about, and administering, the Fund. It was thought that a combined form made for a better process because: i) it made the advice to applicants simpler as there was only one form to explain; ii) it reduced the administrative burden by minimising repetition, streamlining the administrative process, and reducing the numbers of applications which were received; and iii) it gave staff discretion to decide which type of grant was the most appropriate.

11.8 The third argument highlighted the large degree of overlap that exists in the information required to make a decision about an application for a CG and a CCG.

11.9 Finally, it was argued that having complete information in each case allowed a more holistic assessment of the applicant’s needs to be made. This meant that advice, support, and referral to other agencies could be provided in a more appropriate fashion.

Arguments in favour of separate application forms

11.10 There were two main arguments made in favour of separate application forms. These were the obverse of the arguments set out above.

11.11 Respondents who favoured this approach thought it provided a simpler and more straightforward application process both for applicants and for decision makers. These respondents thought separate application forms would reduce mistakes, minimise confusion, improve the ease with which the application process could be audited, provide more clarity, and make the process quicker by allowing the local authority to identify urgent applications. These respondents often referred to the length of the application form (28 pages), which was thought to be a barrier to applying for some people; respondents particularly highlighted the difficulties for some people of providing so much information (e.g. those with learning disabilities, those with mental health problems, the blind and partially sighted, and those without access to credit for a long telephone call).

11.12 The other main reason that respondents gave for preferring separate forms was that the criteria and eligibility requirements for CGs were different to those for CCGs. This meant that the assessment process was distinctive for the two types of grant and applicants for each type of grant should be separately assessed. These respondents thought that separate forms would help improve applicants’ understanding of the two schemes.

11.13 The point was also made that if a combined form is used, there is a risk the level of support offered in relation to each grant may be reduced because the officer knows that the other is also being awarded; this might mean that insufficient funds were granted in both cases.

Wider issues in relation to the application process

11.14 It was thought that it was better to complete the application process, especially for CGs, over the telephone (rather than on the paper form). Respondents said this would speed up the process of application and allow the applicant to be supported by a local authority member of staff; they thought applicants should be encouraged to get support of this kind, and that such support should be available for all applicants.

11.15 Online systems for CCGs were also reported to be widely used, and these were often preferred to paper based applications. There was a suggestion that online forms should be adapted for use on mobile phones, but also a concern that the application process should not discriminate against older people who were not comfortable with using the internet.

11.16 Respondents raised the issue of improving the IT systems which underpin the application process. It was suggested that more could be done to ensure that IT systems would ‘auto-complete’ or ‘pre-populate’ fields in cases where multiple applications were being made; this would reduce duplication an improve efficiency. Sometimes, IT systems ‘crashed’ in the course of an application. This was distressing and frustrating for both applicants and staff.

Information on application form which is not required (Q21)

11.17 Altogether, 28 respondents (25 organisations and 3 individuals) made comments at Question 21. Many of these comments suggested changes and improvements to the form, and have been considered below in relation to the analysis of Question 22.

11.18 There were four main areas where respondents thought the information collected was not necessary for the assessment process. These were:

• Asking ‘how much do you think it will cost?’ (Section 3a) for each item requested when local authorities use approved contractors / retailers to supply items
• Asking the applicant to provide their bank details (p24) when this is not the usual method of paying grants
• Asking for national insurance numbers; respondents noted that having a national insurance number was not an eligibility requirement for SWF and asking for it might discourage applications, especially from refugees
• Asking for information about qualifying benefits, including information about next payment dates; it was thought this information could be checked by the local authority itself via the DWP.

11.19 Other items mentioned, less often, as ones which should be omitted or reconsidered were:

• The two questions on p14 about how much money has been lost or stolen
• The questions relating to the partner – only information about the applicant should be required
• The final question on p11 ‘what have you or your partner tried?’ which it was thought would discourage applications
• Questions about emergency services and household insurance
• Information on the sources of support applicants have tried to access.

Suggested improvements to the application form (Question 22)

11.20 Altogether 35 respondents (32 organisations and 3 individuals) made comments at this question. As indicated earlier, responses to Questions 20-21 also sometimes contained information relevant this question.

11.21 In many cases, the improvements suggested were highly specific, often suggested by one respondent only (e.g. ‘include a central contact number’, ‘blank page for additional information should be towards the end, after ‘other information’’, etc.).

11.22 The two areas which were mentioned for improvement most often by respondents were: to improve the layout, signposting, structure and flow of the application form; and to redraft the preamble and description of eligibility criteria.

11.23 Regarding improvements to the form layout and structure, respondents thought it could be clearer which parts of the application form needed to be completed and which did not. This was linked to the issue of which parts of the form related to an application for a CG, which parts for a CCG, and which parts were common to both. The use of highlights, bold text, and instructions for navigating the form were all thought to be potentially useful in improving the layout. More generally, it was thought the ‘flow’ of the questions could be improved.

11.24 Regarding the preamble, respondents thought that the preamble did not accurately reflect the current situation regarding the eligibility for CGs in terms of qualifying benefits. It was thought that the preamble should be more positive in highlighting what grants can be used for (not just what they cannot be used for) and that the main message should be about the availability of funds for those on a low income with nowhere else to turn.

11.25 Other areas which were mentioned for improvement, less often, were:

• To add in some case studies and examples
• To condense the questions on income (p8-10), especially as the local authority can collect this data from DWP
• To improve the questions relating to applicants who are sanctioned
• To add more detail in relation to prisoners, their intended release date, their prisoner number, and their address
• To add specific questions on transport requirements.