Low Income Winter Heating Assistance: consultation analysis

Executive Summary

Introduction

The Scottish Government has committed to replacing the UK Government's Cold Weather Payment (CWP) of £25 for every 7 day period of very cold weather. From winter 2022, the proposed Low Income Winter Heating Assistance (LIWHA) will see a new £50 winter heating payment paid annually to those low income households currently eligible for the CWP, regardless of the weather.

The consultation on the introduction of LIWHA was open from 1^st December 2021 to 25^th February 2022 and received 119 responses. The 38 consultation questions covered the format, amount and timing of the payment, the removal of the cold spell criteria, eligibility and qualifying criteria, the redetermination and appeals process, and the potential impacts of the policy. In addition, a stakeholder engagement event was held in January 2022.

Overview of proposals for LIWHA

There was broad support for the introduction of LIWHA. Seven in ten respondents (70%) agreed with the proposal to replace the CWP with a new benefit. One fifth (22%) disagreed and one in ten were either unsure or did not answer. Three fifths (61%) agreed that LIWHA is an effective way for the Scottish Government to tackle winter heating costs. One quarter (26%) disagreed and one in ten were unsure. Among the minority who disagreed, the most common view was that removing the cold spell criteria could make some households worse off under the new benefit than under the CWP. Other reasons included a concern that some low income households would miss out on the payment, that LIWHA does not help address fuel poverty, and that the proposed £50 payment is too small.

Just under half of respondents (48%) agreed with the proposed name of Low Income Winter Heating Assistance. Four fifths (39%) disagreed and one in ten (12%) were unsure. The most prevalent reason for disagreement was that the term 'low income' could stigmatise recipients. Several respondents felt the existing Cold Weather Payment name should be retained. They argued this was shorter, more memorable and recognisable.

The existing CWP pays £25 when recipients experience a cold spell between 1 November and 31 March. LIWHA proposes to remove the cold spell requirement for payment. Over three quarters (76%) of respondents agreed with the proposal. One sixth (16%) disagreed and 8% felt unsure. Some who agreed observed that removing the link to cold weather would increase certainty about fuel assistance. A few felt it would give households confidence that money would be available to allow them to put on or turn up their heating. The issue most frequently identified by the minority who disagreed was that removing the cold spell criteria could make some households worse off under LIWHA than under the CWP. A few went on to say this would exacerbate existing fuel poverty in colder areas.

Qualifying benefits

Just under two thirds of respondents (64%) agreed with the proposal to use qualifying benefits to identify eligibility for LIWHA. A quarter (25%) disagreed and 9% were unsure. Several respondents explained they agreed with this approach because they felt it is a relatively clear and simple way to identify those who will benefit most from the scheme and will make it easier for the SG to plan and budget for the payment. The most prevalent issue identified by the quarter of respondents who disagreed was concern that the proposal could exclude some people who need financial support, as not all people on a low income are eligible for or claim state benefits.

Half of respondents (50%) agreed with keeping the current qualifying benefits to determine eligibility for LIWHA. Over a quarter (28%) disagreed and 18% were unsure. In agreeing with the proposal, some respondents commented that, in the majority of cases, the current qualifying benefits will capture low income households experiencing fuel poverty. The most common request from respondents who disagreed with this aspect of the proposal was to add other benefits to the list of qualifying benefits, including Personal Independence Payment (PIP) and Disability Living Allowance (DLA).

The majority of respondents (60%) agreed that the eligibility criteria for LIWHA are clear. Few disagreed (13%) and nearly a quarter (24%) were unsure. Complexity was the most commonly raised issue among those who disagreed. A few respondents described the criteria as 'unclear', 'complex' and in need of simplification.

Qualifying week

Just over two-fifths of respondents (41%) agreed with a proposed qualifying week during which eligible recipients for LIWHA will be identified. One third (34%) disagreed and 23% were unsure. Some supporters observed it makes the benefit easier to administer, particularly in terms of identifying recipients without the need for an application process. The most common reason for disagreement was that people who become eligible after the qualifying week would not receive a LIWHA payment that winter. Respondents argued that individuals' circumstances can change quickly, but the proposals make no provision for those who begin receiving qualifying benefits after the qualifying week.

Timing, amount and format of payment

Views on whether a one-off payment is appropriate for LIWHA were sought in two questions. At each question a majority of respondents supported a one-off payment – 55% at Q9 and 61% at Q21. Reasons for agreement include a view that recipients could plan more easily if they knew the amount and date of payment. The most common theme among those who disagreed with a one-off payment was a call for multiple or split payments. Respondents believed multiple payments would also help recipients with budgeting, particularly for those using on prepayment meters.

A majority of respondents (52%) disagreed with the proposal to make LIWHA payments in February each year; 29% and 16% were not sure. Many who disagreed felt a payment date in February is too late, and that recipients need help earlier in the winter to cover heating costs when cold weather first arrives. Concerns were expressed for people using prepayment meters or unregulated fuels (oil or off-grid gas) who pay for fuel in advance. Among respondents who called for an alternative payment month, the most common suggestion was January, followed by December. Respondents explained that a payment in these months would help to address the concerns about the cost of Christmas and about a February payment being too late.

Respondents were also asked whether they agreed with the proposed £50 LIWHA payment. More than half (52%) disagreed with the proposal, almost a third (31%) agreed, and a sixth (14%) remained unsure. Most prevalent among those who disagreed was a concern that £50 is not enough, particularly given rising energy costs. There was also a concern for those living in areas regularly affected by cold weather, in rural areas, or living in the Highlands and Islands, who typically pay more for fuel.

Just over half (51%) agreed with LIWHA being made as a cash payment. One quarter (27%) disagreed and 21% were unsure. Several expressed various reasons in support of a cash payment – that it is destigmatising, treats the recipient with dignity, empowers decision-making and provides certainty for budgeting. The most common reason for opposing a cash payment was that it could be misused and not spent on fuel or heating costs. Many believed payment should be made directly to energy suppliers.

Redetermination and appeals

There was a high level of agreement with the proposal that recipients have 31 days to request a redetermination. Over seven in ten (71%) agreed, 13% disagreed, 10% were unsure and 6% did not answer. The minority of respondents who disagreed commonly felt additional time was needed. A few described the potential difficulties that groups who may lack confidence or need additional support, such as disabled people, older people, digitally excluded groups and rural communities, could face in meeting this deadline.

Two thirds of respondents (66%) agreed with the proposal that Social Security Scotland should have a period of 16 working days to consider a redetermination of LIWHA. Fifteen per cent disagreed, 11% were unsure and 8% did not answer this question. Some were concerned that it is too long especially for people who need the money to pay for heating.

Other impacts and Impact Assessments

Several respondents addressed the need to ensure people with protected characteristics are both aware of LIWHA and have access to information. A few believed that LIWHA could positively impact recipients with disabilities, noting this group may spend more time at home and have higher fuel costs. Some noted that LIWHA could increase incomes for eligible families, thereby improving the health, wellbeing and development of children.

Respondents cited several challenges faced by island communities which contribute to higher rates of fuel poverty. These include the comparatively higher cost of fuel and energy supplies and the poor energy efficiency of homes. Some respondents called for LIWHA to have a greater recognition and consideration of these challenges.

Conclusions

This report provides a high-level summary of respondents' perspectives. Together, these responses are an essential evidence base for the Scottish Government to draw on when finalising LIWHA to ensure it is delivered with dignity, respect and fairness.

The range of views identified in the consultation provide a useful steer for any further development of LIWHA. However, given some of the variation in the views, priorities and concerns expressed in consultation responses, it is likely that any changes to the proposals will not satisfy all stakeholders.