Best Start Grant: analysis of consultation responses

Maternity and New Baby Payment

The consultation paper proposed that BSG eligibility will be determined via a series of tests carried out on the date of application. The eligibility conditions set out include that:

• the application is received within the relevant application window;
• no equivalent payment of an SSMG or BSG has been or is due to be made;
• the applicant is habitually resident in Scotland, and is entitled to be living in Scotland;
• the applicant is, or is the partner of, someone who is going to or has had a baby, or meets the responsibility test for the child by reason other than being a biological parent; and
• the applicant meets the test for financial circumstances.

Young parents, namely those under the age of 18, would not be required to meet the financial eligibility test.

The existing approach used for the SSMG would be applied, where the grandparent (or other carer) becomes the eligible person in cases where the parent is under 16, or is aged 18 or 19 and in training or non-advanced education, and where they are still in receipt of tax credits or Universal Credit ( UC) or Child Benefit ( CB) for the young parent.

Additional information was provided against each of the eligibility tests, including any required definitions as well as the rationale for choosing certain options over possible alternatives. Consultation questions focused on the last three tests and around the proposals for young parents.

Q1. We have proposed that applicants must be habitually resident in Scotland to qualify. Do you agree with this approach?

Response	Number	Percentage
Yes	32	63%
No	2	4%
Don't Know	1	2%
No quantitative response	16	31%
Total	51	100%

Many respondents supported the proposal that applicants must be habitually resident in Scotland to qualify for the BSG. Generally these respondents felt that this was a fair approach, consistent with tests for other benefits, and was necessary to ensure only those who live in Scotland are eligible for the payments:

"As it is being funded by the Scottish Government this approach seems fair." (Individual)

"Habitual residency test is essential as this gives a consistent approach to other UK benefits." (Organisation)

Some of those who agreed with the residency test overall did, however, have some concerns. A few suggested that clarification over the definition of 'habitually resident' may be required for claimants (including the tenure to which it referred), while others suggested that clear guidance would be required for those administering the grant:

"There must be clear guidance for decision makers and applicants on applying the habitual residency test." (Organisation)

"Given the potential for confusion among both claimants and decision-makers regarding the habitual residency requirements, a clearly stated definition of habitual residency within the regulations would help to improve decision-making processes and bring the clarity required." (Organisation).

One respondent commented that there was a clear need for all applications to be treated on a case-by-case basis to reflect the diversity of applications:

"Additionally, staff at the new Social Security Agency should have a clear cut objective to determine and assess cases on an individual and subjective basis. This should include equality data pertaining to gender, particularly around the likes of the BSG… As tests for status will most likely consider women for whom English is not their primary language, overtures should be in place for this. This should be done with utmost dignity and not seen as a way of testing people in order to "catch them out". Those who will be subject to these tests should be informed in a timely manner of the outcome and given advice on contacts from independent agencies and advice services who can help given the complexity of the test." (Organisation)

Meanwhile, two respondents who agreed with the approach in principle, highlighted the vulnerability of asylum seekers:

"We agree with the general principle that a claimant should be habitually resident in Scotland to qualify. However, some asylum seekers may not qualify at the time of application because they will not have a right to reside but this may be subsequently granted. This could potentially mean that the timing of a Home Office decision could cause someone to lose out." (Organisation)

"We appreciate that those seeking asylum are not eligible for non-contributory benefits under current legislation. However, this group is likely to be financially vulnerable and the devolution of this benefit would provide an opportunity to provide some support for this group." (Organisation)

Both respondents who disagreed with the residency test, plus the respondent who stated 'don't know', also cited the implications of this test for refugees, asylum seekers and migrants:

"I am aware that some migrant families who settle in Scotland are disadvantaged if not habitually resident at time of application. This means that all children born in Scotland are not born equal." (Individual).

"Provision should be made for asylum seekers and refugees to access this grant or the parts of it for as long as they are here and awaiting residential status." (Individual).

"We are concerned this excludes groups such as Refugees and Asylum Seekers or others who might not be considered to be habitually resident in Scotland but would find this entitlement beneficial." (Organisation).

One organisation noted that clear data sharing protocols between the Scottish and UK Governments would be necessary to ensure that individuals "do not fall through the gaps."

Among the 16 respondents that did not specify whether they supported the residency test or not, mixed views were expressed. Some supported the test in principle, while others had concerns around how it would work in practice, particularly for those aged under 18:

"The burden of having to provide evidence of residence is going to be highest on those under 18 who are not claiming a qualifying benefit in their own right… Careful consideration should be given to what will suffice as evidence for this claimant group. It may be worth considering that in some cases, evidence could be obtained through the link to parents/responsible carer's claims for qualifying benefits. However, parents/carers may not always be in receipt of these benefits. An alternative source of evidence could be an education establishment being able to provide this evidence." (Organisation)

"More information is also required on the 'separate residence test' for under 18s described in the consultation document (para 29). Reassurance [is needed] that there will be no separate "right to reside" requirement in relation to the Best Start Grant for under 18s. [There are] numerous examples of under 18s who have failed the habitual residence test for DWP benefits due to not having the right to reside. This has been a particular issue for young EEA nationals who are refused the right to reside despite having been in the UK/Scotland for several years." (Organisation)

A few questioned the need for the habitual residency test when other benefits, such as Child Benefit, Child Tax Credit and Working Tax Credit were noted to have an ordinary residence requirement. It was also highlighted that the SSMG (which the BSG seeks to replace) implements no such residence requirement. As such, there were suggestions that the ordinary residence requirement would be more suitable, less onerous for applicants, and more compatible with other qualifying benefits:

"We would seek clarification on why the Scottish Government consider the potentially more onerous habitual residence test should be imported to the BSG. We believe such importation could lead to an additional barrier to the BSG for already hard pushed parents. In effect, we would seek to persuade the Scottish Government to import the 'ordinary residence' test as used in the UK system as we believe it would be sufficient in order to satisfy Scottish residence for BSG claimants." (Organisation).

Some also sought clarification on how the requirement would work in practice for those moving to Scotland from other parts of the UK, for EU nationals and for those in exceptional circumstances:

"The regulations state that claimants should be habitually resident in Scotland. However claimants may qualify through DWP passporting benefits which rely on being habitually resident in the UK. There may be some confusion arising from this." (Organisation)

"There is the potential for this to cause confusion in relation, for example, to applicants who have recently moved to Scotland from another part of the UK… The Scottish Government should also consider whether the regulations can allow for those in exceptional need to access BSG despite not being able to establish habitual residence. Several cases show that women who have lived in Scotland for many years can be left without a right to reside as a result of relationship breakdown and domestic abuse or that they are incorrectly deemed not to have a right to reside as a result of DWP error." (Organisation)

"Additionally this could cause problems with migrant and EU nationals." (Organisation)

One respondent noted that appeals for habitual residence need to be taken into account, and so flexibility around the timescales would be necessary:

"…some flexibility should be given on this criterion, for example an appeal on habitual residency can take months, so when HR is awarded a claim should be allowed outwith the Best Start application window. Thought should be given to whether the time limit for applications could be extended until the result of appropriate UK benefit applications or challenges has been concluded." (Organisation)

One respondent also sought clarification on how a prison sentence (and subsequent care arrangements for children) may impact upon eligibility:

"It is not clear from the consultation how a prison sentence may impact on the residency test. If a parent would otherwise meet the eligibility criteria for the grant and has been habitually resident in Scotland before going to prison, then it is our view that serving a prison sentence in another jurisdiction should not negatively impact on their entitlement to the grant. Nor should their entitlement be negatively affected if a child, who was usually living with a parent in Scotland before they went to prison, is cared for in another jurisdiction (perhaps as a consequence of the imprisonment) while their parent is in a Scottish prison." (Organisation)

Q2. There are two alternative tests [to establish responsibility for a child] set out in the consultation: (1) receipt of Child Benefit and, where relevant, a care order; or (2) a test based on receipt of either Universal Credit or Child Tax Credit, or Child Benefit. Which is your preferred test, Test 1 or Test 2?

Response	Number	Percentage
Test 1	14	28%
Test 2	21	41%
No quantitative response	16	31%
Total	51	100%

It is important to note that there appears to have been some misunderstanding around the interpretation of this question. The consultation document highlights that applicants will have to be on a qualifying benefit (indicating that they are on a low income) while also proposing the use of certain benefits awarded to people who have children to evidence responsibility for a child. However, this appears to have been misunderstood by some respondents who focused more on qualifying benefits to prove financial circumstances rather than responsibility for a child.

A slightly greater number of respondents indicated that they preferred Test 2. Some noted this was because it allowed the BSG to be better targeted towards those on low incomes:

"Everyone with a child receives Child Benefit but not everyone who is expecting a child will need the Best Start Grant. The money should be directed to those who need it the most and therefore it should be based on receipt of Universal Credit, Child Tax Credit or Child Benefit or a mixture of those." (Organisation)

It was also felt that Test 2 was simpler, more efficient, allowed for greater flexibility in determining responsibility (and so should capture more of those who are eligible), and also provided flexibility for applicants to provide evidence/support for their application. Removing barriers to application which might be based on concerns around the complexity of the process was seen as key:

"This test [Test 2] is more straightforward for claimants to understand their entitlement. At the present time many claimants are confused about their entitlements to CTC/ UC on the birth of their third child and some think that they are not entitled to CB either under the 3rd child rule. A test for BSG entitlement based on CB alone (as per Test 1) in these circumstances might therefore prove to be insufficient, creating a barrier to uptake, including receipt of all three benefits would carry a stronger indication of entitlement." (Organisation)

"[Test 2] presents more opportunities for families in a range of circumstances to be eligible. Families can be complex and the Scottish Government need to carefully consider young children who may slip through the net in terms of eligibility to BSG. We would argue that any care experienced person who has a young child should be eligible for the BSG and does not need a qualifying benefit to be eligible." (Organisation)

Kinship care arrangements were given particular consideration by a number of respondents keen to ensure that the varying arrangements for kinship care (both formal and informal) are captured by the BSG eligibility criteria/tests. Some felt that Test 2 was more appropriate for kinship carers as it considered a broader range of benefits, whereas Test 1 could create challenges and eligibility issues for kinship carers, particularly where more informal arrangements were in place and there is no formal court order:

"It [Test 2] also means that it is more likely that kinship carers are eligible to receive Best Start Grant for children in their care, given the broader range of benefits which would capture a greater number of kinship carers with informal arrangements." (Organisation)

"There is an issue for kinship carers having a qualifying benefit and/or court order in time to receive the BSG. It is not unusual for the payment of Child Benefit and Child Tax Credits to be retained by a parent… Similarly court orders can be a lengthy and costly process that not all families decide to pursue… Therefore, we consider Test 1 is more problematic for kinship carers." (Organisation)

Some also noted that in all formal kinship care arrangements social work services would be making kinship care payments and could therefore provide information and evidence of responsibility for the child. It was also noted that some local authorities allow less formal arrangements to be notified to social work, again facilitating receipt of other passported benefits:

"As it stands Test 1 requires kinship carers to have a kinship order. This is not something that kinship carers ordinarily obtain, partly due to costs involved and also because of a reluctance to go through a court procedure. However all formal kinship carers will have had the kinship arrangement put in place by Social Work Services, as such Social Work Services could provide confirmation that they are making kinship care payments. This should be sufficient evidence of a kinship care arrangement without the need for an order." (Organisation)

Others highlighted that Test 1 was not preferable as its reliance on Child Benefit risked the BSG being paid to someone other than the main carer:

"Basing eligibility on Child Tax Credit or Universal Credit should help ensure a safeguard against concerns raised about cases where the partner receiving Child Benefit is not in reality the main carer." (Organisation)

"As the second test contains scope for both child benefit and child tax credit, women have noted that this may be the best approach. Given that child benefit does not necessarily have to be received by the female in the household, allowing only this as a test may leave vulnerable women open to abuse and financial hardship." (Organisation)

One respondent, generally in favour of Test 2, noted that consideration would need to be given, at least in the short term, to legacy DWP benefits as not all applicants may have migrated across to Universal Credit before the BSG is implemented. Two respondents also felt that in order to align with the Scottish Government's policy objectives, consideration should be given to low income earners and in-work poverty in order to ensure these children are supported via the BSG.

Of those that preferred Test 1, this was generally cited as being an appropriate check on responsibility, as well as easier for both applicants and the administration of the BSG. Specifically, respondents felt that Child Benefit was already widely known and understood by parents and would therefore seem less confusing to applicants:

"We feel basing responsibility on Child Benefit - with the flexibility outlined for cases where the individual is not in receipt of Child Benefit - will be both easier for Social Security Scotland to administer, and for claimants to understand." (Organisation)

"This is the best option as whoever has responsibility for care of the child should receive the grant. Payments of benefits can be disputed between family members especially if a child has been removed from a parent therefore the care order would override whoever was in receipt of the benefit. Test 1 would ensure that the correct person would receive the grant." (Organisation)

Others who preferred Test 1 highlighted shortcomings or complications arising from Test 2, including:

"Tax credit gets a bit confusing with 3rd child, so best to stay with child benefit test as HMRC also do." (Organisation)

"Universal Credit system is flawed. Child Tax Credit is not always applied for, particularly with parents who have received overpayments and are liable to pay back repayments." (Individual)

"It is our view that the complexity and delays associated with applications for Universal Credit or Child Tax Credit mean it would not be appropriate or effective to use these benefits to establish responsibility for a child." (Organisation)

"Test 1 would be easier to administer and increase BSG take-up. Delays and maladministration are common within the CTC and UC systems leaving many people waiting for awards to be processed. This can lead to a significant time lag in people being able to establish they are in receipt of CTC and UC, meaning some people would be unable to claim BSG within the time limit, or have to make a claim for BSG before they received confirmation of payment of the qualifying benefit. This is potentially a significant barrier to BSG take-up and means some people do not claim due to the confusion caused by the overlap of the devolved and reserved benefit system." (Organisation)

Three respondents also indicated that they would like to see a combined approach, with both tests operational. One respondent felt that Test 1 could operate as the main test, but with Test 2 being optional for those that did not qualify at Test 1:

"We believe it should be a combination of both tests in order to be beneficial to as many people as possible." (Organisation)

"In order to ensure that as many children as possible benefit from the grant, we would support a tiered approach, with Test 1 as the primary test and parents/carers able to qualify through Test 2 if they are unable to meet Test 1." (Organisation)

Finally, one respondent discussed the difficulties with a benefits test being used to establish responsibility for parents (particularly mothers) who are serving a prison sentence:

"It may also be helpful if mothers who are pregnant or give birth in prison are allowed to nominate someone to receive the Maternity and New Baby Grant on their behalf without that person having to meet eligibility criteria in their own right. While this may reduce the rigour of the test in these particular circumstances, the number of pregnancies and births to mothers in prison in Scotland is low, while the risk of these babies experiencing health and social inequalities is very high." (Organisation)

Q3. We have proposed that qualifications by UC should be an award of more than £0 in the month in which the application is made. Do you agree with this approach?

Response	Number	Percentage
Yes	17	33%
No	12	24%
Don't Know	7	14%
No quantitative response	15	29%
Total	51	100%

Slightly more respondents agreed with this approach than disagreed. Those who agreed typically felt that the application timescales were sufficient to allow applicants with more irregular incomes to submit appropriate applications:

"Since the new BSG rules allow for applications to be made between the 24th week of pregnancy and 6 months after the birth it gives claimants much greater flexibility as when to make their claim and to also choose a period where UC is actually being received. The 2 month rule will also provide a further safety net to cater for fluctuating income within that period." (Organisation)

"This will make it easier for claimants to be successful and given the long window of application then it can be made to take account of any extra hours being claimed if they are a 'one off', thereby increasing household income legitimately." (Individual)

Some respondents also noted that it would be important to make the eligibility test and timescale clear to applicants:

"[We] would suggest that information targeting parents includes a statement that application can be made during the application timescale if and when their family income/circumstances changes, e.g. a lowering of family income to within the Best Start Grant income threshold." (Organisation)

A number of respondents, including those who broadly supported the proposal and those who disagreed with it, highlighted irregular incomes as a potentially confounding factor which may create difficulties for some applicants:

"Agree with the test, but don't agree that people in receipt of UC with 2 months £0 UC showing, do not qualify. This is unfair for people on fluctuating incomes, as they may have qualified for tax credits which is based on annual income." (Organisation)

Several respondents pointed out that weekly, four weekly pay, or changes to payment schedules due to Christmas/Bank Holidays could result in two wages being paid within one month, thus leading to a £0 award under Universal Credit, or that issues around maternity pay, seasonal work, zero hours contracts, etc. could all impact on Universal Credit payments within the timescale proposed, and thus lead to rejected applications:

"Universal Credit is a monthly benefit and as such working claimants who are paid 13 or 52 times in a year (4 weekly or weekly) will have one assessment period where they get 0 due to a so called double payment in the previous month. If the application/birth of their child happens to fall around this time this could result in refusal of the grant due to a misrepresentation of the parental income." (Individual)

"[We] would caution in areas particularly in rural Scotland, where seasonal and zero hours contracts are more prevalent within the economy and as a consequence, UC awards may be £0 for a number of months." (Organisation)

"We think it needs to be widened more than to 3 months as fluctuations with maternity pay, zero hours contracts etc. could cause confusion." (Organisation)

Sanctions and debt recovery issues affecting the amount of Universal Credit paid were also seen to have a potential impact for BSG applications, with one respondent highlighting that to refuse the BSG on this basis would intensify people's vulnerability:

"It may also be possible for an individual to be sanctioned to the extent that there is an award of £0. In such circumstances the poverty that people may be experiencing would increase if that individual is consequently deemed ineligible for a Best Start Grant. Again, the simplest way of addressing this would be for the qualification to be eligibility for a Universal Credit award, rather than specifying that the award must be more than £0." (Organisation)

"Yes, however consideration should be given to the circumstances surrounding a nil award of Universal Credit. A claimant may have a nil award due to a managed payment arrangement or debt recovery/advance deductions." (Organisation)

Two respondents highlighted potential complications (and the likely exclusion of eligible BSG applicants) resulting from a new surplus earnings rule for Universal Credit (introduced on 11/04/18):

"The new rule seeks to 'level out' fluctuating earnings for the purpose of assessing UC income but has been widely criticised for not being fit for purpose… One of the main contentious aspects of the policy is that it requires UC claimants with fluctuating earnings to make repeated 'bound to fail' claims for UC in order to 'erode' a surplus earnings addition. The rule is complex/difficult to understand and, as stressed by the SSAC, is likely to put off claims for UC/disadvantage UC claimants with fluctuating earnings." (Organisation)

"The surplus earnings regulations will mean that many low income claimants will potentially not be entitled to Universal Credit due to income received in a previous assessment period (potentially up to six months ago)." (Organisation)

Some also highlighted that the Universal Credit system was changing to remove those receiving £0 awards to be classed as receiving the benefit, and that the inclusion of this criteria would become confusing for applicants:

"We believe that the phrasing of this qualification has the potential to cause confusion among claimants, advisers and decision-makers. It is our understanding that in the full service version of Universal Credit, cases where there is an award of £0 - due to the claimants income exceeding the maximum amount permitted for a Universal Credit claim - are closed, and the individual is no longer considered to have a Universal Credit claim (and must make a new claim at such a time as when their income falls in line with the eligibility threshold). Given this, it would be simpler and more easily understood for the qualification to simply be eligibility for a Universal Credit award." (Organisation)

Similarly, another respondent felt that eligibility should simply be based on whether an applicant was in receipt of Universal Credit, and not dependent upon the scale of the award:

"…being in receipt of UC even for those with a £0 award in one of the months assessed should enable qualification. This would include those on an income which fluctuates above and below the UC eligibility threshold and those who may only recently have exited the UC qualifying income bracket. As both of these groups are likely to be financially vulnerable." (Organisation)

Some respondents also highlighted the difficulties in using the Universal Credit system as the basis of such eligibility criteria generally, noting that low income families could be ineligible for Universal Credit or subject to lengthy decision times, and thus refused the BSG, due to anomalies in the way Universal Credit is assessed rather than their earnings. For example, they noted this could affect the self-employed and those waiting to be assessed as having limited capability for work. They also noted that the design of Universal Credit was problematic when used as a means of assessing entitlement for other benefits:

"Universal Credit is also problematic in its design when being used as a means to assess entitlement to other benefits, as it is not until the assessment period actually finishes that entitlement for that month is known. We believe this makes UC an unreliable basis for assessing an individual's right to other benefits, and would be very concerned that people who should receive a BSG will miss out on what they are entitled to if this approach is adopted." (Organisation)

One respondent also discussed the impact of the Universal Credit system on women. They argued that the ongoing confusion surrounding Universal Credit and the changes in payments from month to month have left women at a 'severe disadvantage', which could have an impact on BSG applications. They felt that other eligibility criteria should be considered where Universal Credit awards had been £0:

"If the qualification of over £0 is kept, it is crucial that there are other ways that people may claim. Given that the BSG is to be a key marker in alleviating child poverty, it must be communicated that when application is made it will only be taken if this criteria is met." (Organisation)

One respondent felt that the consideration of just two months income was disproportionate to the overall application windows for each BSG payment:

"It could be argued however that the application window of 'within two months of experiencing low income' is a tight timescale in comparison to the general application windows for each payment of the Best Start Grant… We would urge the Scottish Government to extend the 2 month window from when people experience low income, as these individuals may need additional time to access information and obtain support to complete their applications." (Organisation)

Again, one respondent outlined the implications that the proposal around benefit awards might have for prisoners. They indicated that the timescale for the qualification via Universal Credit needed to be "extended to within at least a few months of the application being made" so that families have time to put their financial affairs in order following a family member's imprisonment. They also noted that "the requirements to have access to a bank account and to receive [ BACS] payments in arrears present challenges for those leaving prison" and indicated that prisoners would need help to make the necessary arrangements in advance of their release.

Q4. We have proposed that in cases where the parent is under the age of 16, or is 18 or 19 and the grandparent (or another carer) is still in receipt of tax credit or UC because the parent is still in training or non-advanced education, the grandparent or carer will be the eligible person. Do you agree with this approach?

Response	Number	Percentage
Yes	23	45%
No	8	16%
Don't Know	3	6%
No quantitative response	17	33%
Total	51	100%

Just under half of the respondents indicated that they agreed with this proposal. A further four of those that did not provide an answer at the quantitative element, did however express general support for the proposals within their qualitative responses.

Generally, respondents felt that this approach was sensible, was consistent with Child Benefit guidance and procedures, and would be the easiest approach to administer and for applicants to understand. It was also felt by some that this approach would help ensure that the grant would be spent on the child:

"This would hopefully ensure monies awarded are best spent on the child priorities." (Individual)

Others, however, felt that while this would assist in the application, and may help ensure the money is spent as intended, there were calls for the young parents to be granted greater responsibility, where appropriate:

"We are concerned that this may not be empowering for the new parent and feel [an] option should be pursued so the parent can receive the BSG payment directly for their child." (Organisation)

This was particularly the case for dependent 18 and 19 year olds, who were generally considered not to need the same level of support as younger parents:

"In cases where 18 and 19 year old parents are in training or non-advanced education, we would recommend that payments are made directly to them rather than to their parents ( i.e. the grandparents of the child) or carers. Such an approach would ensure the autonomy of the young person and reflect the fact that they do not have the same need to be supported in how they utilise the grant." (Organisation)

Several respondents felt that, as well as being important for self-efficacy, this would make the award less open to potential abuse from coercive grandparents, and would be beneficial in situations where relationships between the new parent and the child's grandparents are strained or estranged.

One respondent also noted that this approach largely worked for other benefits, but felt that clear guidance for applicants would be required, and also consideration of individual circumstances where there is a risk of financial abuse on the part of the person receiving the BSG:

"Normally there are very few problems associated with awarding grandparents the tax credits and the Sure Start Grant on the parent's behalf, however the guidance and communication to claimants will require to be robust to avoid barriers to uptake. There will also require to be consideration taken to the fluctuating nature of family relationships to avoid financial abuse." (Organisation)

One final supportive respondent highlighted issues around implicit and explicit consent, and discussed potential barriers created by the need for explicit consent:

"The regulations are not specific or clear in relation to the concepts and practice of implicit versus explicit consent. The issue of explicit consent requirements introduced/enforced across the UK's welfare reform agenda, has created an additional burden, additional delay and significant barriers… for some individuals, who through circumstance find that they are unable to self-advocate. In our experience, [some people] find themselves literally incapable of communicating directly with any representative of the Department for Work and Pensions, or HMRC Tax Credits, as a direct consequence of multiple factors which may include: negative experiences of the DWP; fear and acute anxiety; poor mental health; emotional and physical exhaustion; emotional distress; low self-esteem. [We] would welcome clarity about implicit and explicit consent within the Best Start Grant regulations." (Organisation)

Eight respondents stated they disagreed with the proposal, and a further one respondent who did not provide a quantitative response indicated explicitly in the qualitative comments that they disagreed. The main sentiments expressed were similar concerns to those above. Some felt that the young person should be trusted with the responsibility of receiving the grant and spending this in the best interests of their child, and/or that complicated family situations could mean that it was not always suitable to pay the money to them rather than directly to the young person:

"No, we are not clear on the reasoning behind this proposal and we do not think this complies with a rights based approach. In line with promoting and protecting children's rights the parent, regardless of their age, should be the eligible person." (Organisation)

"We would recommend that the young parent should receive the grant to acknowledge their new responsibility, respect their autonomy and to give the message that we trust them to be considered in their use of the grant. Accompanying information should list sources of support and advice for the young parent on how to best use the grant, which can include their parent/guardian." (Organisation)

Views were expressed that the monies should instead be paid directly to the young parent's bank account to make the most direct provision/ensure that the payment is definitely received by the eligible person. Again, this was seen as especially important in cases where domestic or other abuse/power struggles exist in family relationships:

"It leaves those who are fleeing domestic abuse, especially coercive control or in forced early marriages or partnerships at a disadvantage. Young adults who are in higher education and parents need to be financially independent and not reliant on older relatives to help direct and oversee their finances." (Organisation)

One respondent also questioned how the eligibility and payment would work where the young parent was in care, and felt this may expose a gap in the provision:

"For young parents who are looked after themselves, there is a further complication of who the money would be transferred to. We would be very concerned if an expectant young mum in care did not receive this financial support because the regulations do not take fully into account their circumstances." (Organisation)

Two respondents requested that the Scottish Government consider extending the age limit for this level of eligibility to all those under 20 years old:

"We ask the Scottish Government to consider extending the eligibility to ensure that all under 20s are eligible for the Grant. This would simplify the current position and ensure that all under 20s are eligible in their own right." (Organisation)

One respondent also felt there was a need for clarification around when applicants' eligibility would cease (based on age), and that any applications made by young parents in their own right should not be detrimental in terms of the timetable available for the grandparent/carer to then claim later:

"[We] believe it would be fairer to specify that the applicant should be or have been under 18 (or 20 for dependents) at some point during the application window. This would ensure that all those eligible would benefit from the extended application window. There should [also] be a provision so that when a dependent young mother claims in own right by mistake, a later claim by the grandparent (or other carer) should be linked with that first application to ensure they do not miss out due to the time limit." (Organisation)