Devolution of Community Care Grants and Crisis Loans: Analysis of consultation responses

8 Conclusions

8.1 Devolution of the Social Fund was welcomed as an opportunity for the Scottish Government to remedy the deficiencies and complexities of the existing system and to secure better integration with other aspects of welfare and public policy in Scotland. It was seen as an important step in tackling the way in which the current welfare system undermines other aspects of Scottish Government policy.

Qualified endorsement for a single grant fund

8.2 There was qualified endorsement of the proposal that the successor arrangements should operate a single grant fund. This was seen to offer financial benefits, both to applicants and organisations, by reducing complexity, improving effectiveness, lowering delivery and administration costs and maximising available resources. This approach was also seen to fit well with other key Scottish Government policies.

A need for more information and concerns about funding

8.3 There was a common desire to have more information about the parameters of the future system and a number of caveats in relation to the level of funding, eligibility criteria, the balance of demand and supply; ring-fencing of funds, financial risk to local authorities and the interface with forthcoming welfare benefit changes. Concerns about equalities and accessibility contributed to uncertainty; respondents wanted more clarity about how the successor arrangements will address the needs of people with protected characteristics under the Equality Act.

Access to low interest loans

8.4 Those that did not clearly endorse the option of a single grant fund saw benefits in running a system of both grants and loans. The key advantage of loans was in recycling funds back into the system.

8.5 A major concern was that successor arrangements would not address the current lack of affordable credit, resulting in applicants being forced to turn to high-cost and risky options for borrowing. Respondents called for a Scotland-wide approach to support the development of affordable credit.

Scope for both: preferred delivery arrangements and channels

8.6 Further information and clarification on the level of funding to be available were widely requested to inform judgements about the best way to deliver the service. About a third of respondents gave no clear view on this aspect of the successor arrangements. However, central or local delivery were not always seen as mutually exclusive options.

8.7 Overall where a view was given, the option of local delivery was preferred, particularly by local authorities, none of whom clearly supported central delivery. Local delivery was seen to offer less scope for economies of scale, but better value for money by delivering a client-focused outcome. Whilst local delivery might best ensure a more client-focused service, this goal was seen to be inextricably linked to the issue of adequacy of funding and the need for clarity about where these costs will fall. Local authorities were most widely proposed to take on the successor arrangements at the local level. A number of issues of implementation for local authorities were highlighted.

8.8 Overall, 12 out of 50 respondents favoured central delivery; almost all of which were third sector organisations. Central delivery was seen to be a more cost-efficient and fair model, allowing greater funds to be available to meet need and avoid a 'postcode lottery'. There was an expectation that even within a centralised system, a number of local authority services and other support providers would still be involved.

Retain a client focus: delivery channels

8.9 Whether under a central or local system, a blend of delivery channels was seen to best ensure a tailored service to assist the most vulnerable, to promote accessibility of the service, to give choice and to meet a variety of needs. Having a range of ways in which to access the Fund was seen as particularly essential for disabled people including those with sensory impairments, learning difficulties and mental health problems. Face-to-face contact was felt to be vital for ensuring equity of access, improving the quality of customer service and decision-making.

8.10 A local service was often cited as a potential gateway to a wider range of services and support and offering the prospect of a more holistic and tailored response to needs.

Eligibility: a focus on needs

8.11 The idea that either groups or events should be the focus of eligibility was challenged. Ideally, eligibility and prioritisation should be based on individual need and the immediacy and extent of any threat to the individual and their families' health and wellbeing. Any definitions should be seen as providing guidance rather than being prescriptive. Respondents generally agreed with a focus on early intervention but felt that should not prevent providing assistance to those in greatest need.

8.12 Despite these caveats, respondents did name groups or events that they felt should be the focus of the successor arrangements and a number of life events that households on a low income or in persistent poverty would struggle to manage.

Offer both grants and goods

8.13 The option of both goods and grants was broadly supported to enable individual circumstances to be addressed, while giving people choice and offering flexibility.

8.14 The advantage of grants was that they enable personal choice, which helps to empower individuals and promote financial capability. The provision of grants would also support local economies.

8.15 The provision of goods would provide the potential for savings through bulk purchasing and through avoiding the inappropriate spending of cash payments. Alternatives to goods-only provision would be to offer vouchers or a supervised-spend system. The main disadvantage of providing goods was that it limited individual choice and personal responsibility.

8.16 The types of goods that should be provided included a range of white goods, furniture and other household items seen as essential to furnish a home. It was seen to be important that goods provision was flexible to meet the specific needs of individuals with disabilities.

Provide optional support and advice

8.17 Respondents were generally in favour of offering other types of support (such as budgeting advice) with the strong caveat that such support should not be compulsory.

Effective appeals

8.18 The successor arrangements were seen to offer an opportunity to establish an independent, quick and timely, fully accessible and transparent appeals system. By getting it right at the application stage, the volume of appeals could be substantially reduced.

8.19 There was a general call for provision for independent review under the successor arrangements.

8.20 Access to independent representation or advocacy was seen to be an important part of an appeals process in supporting access to justice and directly affecting the outcome of appeals.

8.21 The appeals system also needs to be adequately resourced. Decisions about delivery arrangements will have implications for the appeals process, and the resourcing of independent representation.

8.22 There is also a need for transparent scrutiny of appeals processes, including the level of appeals, reasons for appeal and monitoring of trends in decisions. This information must be used to inform future training for staff and also to inform policy makers.

Other issues and next steps

8.23 A number of practical issues regarding implementation were raised in order to have a fully-operational grant system in place across Scotland by 1 April 2013 at the same time as other major welfare reforms. These reforms will themselves need to be taken into account, particularly the introduction of Universal Credit and there will need to be clarification with DWP about how the devolved Social Fund's decision-making apparatus will interact with those of DWP and how working arrangements can be improved.

8.24 It was suggested that the Scottish Government should give careful consideration to the name of the new scheme, to avoid the stigma of the Social Fund. There was a view that the low take-up rates of some groups could be improved by such a simple measure.

8.25 Local authority and other statutory public sector respondents, in particular, felt that the consultation document did not provide sufficient information to enable fully informed responses and sought further information and more consultation to understand how the devolved fund would work in practice, including details about how it might impact on specific equalities groups. There were very few responses from non-local authority public organisations such as the NHS.

8.26 Some respondents expressed a willingness to be involved further in any working group or to review any draft regulations or proposals and requested that any working parties should include representatives of front-line staff working with relevant client groups.