Scottish Carer's Assistance: consultation analysis

Executive Summary

Background

The Social Security (Scotland) Act 2018 was a major piece of devolved legislation and laid the foundations for the delivery of a range of benefits. Twelve benefits have already been delivered in Scotland and the Carer's Allowance Supplement was the first payment introduced under the Scottish Government's new social security powers. The Scottish Government plans to begin the roll out of Scottish Carer's Assistance from the end of 2023, with full national introduction planned for spring 2024.

Scottish Carer's Assistance will replace Carer's Allowance and will support over 80,000 people who provide 35+ hours per week of care to individuals receiving certain disability benefits.

In February 2022, the Scottish Government launched a consultation seeking views on proposals ahead of the introduction of Scottish Carer's Assistance. This consultation paper outlined the Scottish Government's proposals for how Scottish Carer's Assistance will look when it first launches, for a new extra payment for those who care for more than one person and the future of Carer's Allowance Supplement and set out five priority proposals for future change.

In total, there were 192 responses to the consultation, of which 41 were designated from organisations and 151 from individuals.

Key Themes

A number of key themes were evident across consultation questions and consultation events as well as across respondent groups.

Overall, Carer's Allowance as currently delivered by the Department for Work and Pensions was seen by many respondents to be complicated, difficult to understand in terms of entitlements, hard to navigate, lacking in transparency and administratively burdensome in terms of making applications and keeping the Department for Work and Pensions up to date with any changes in circumstances. As such, the proposals outlined in the consultation paper were welcomed and were, in the main, seen to recognise carers and their caring role, as well as going some way to help alleviate the poverty experienced by many carers. In general, the approach outlined in the consultation paper was perceived to be more sympathetic, flexible, person-centred and an acknowledgement of the difficult and challenging role faced by carers.

However, some respondents felt the proposals did not go far enough, with a few comments that all carers should be recognised for their caring role, that many existing carers will not be eligible for support under these proposals and that the proposed changes should be extended further. For example, while respondents were positive about the Carer's Additional Person Payment, there were many comments that this should be more than the proposed £10 per week.

There were some references to the amounts of money saved by carers for the public purse and comments on the effective hourly rate paid to carers through Carer's Allowance which was perceived to be very low in comparison to the national living wage or the real living wage. There were some calls for all carers to be paid the national living wage or real living wage for their hours of caring.

Key themes emerging across the consultation included:

• The need for information to be provided in a variety of different formats and utilising a range of different channels to optimise accessibility. For example, there were some calls for easily accessible information on entitlement to other benefits.
• A number of respondents – particularly organisations – asked for more support to be available to carers. There were some specific suggestions for carers to be linked to carer centres for advice and support, for example, in providing information on benefits.
• Respondents want to see fast, straightforward and transparent processes when applying for Scottish Carer's Assistance and would like to be able to find out more about other related benefits to which they may be entitled.
• Respondents would also like to see information provided about the impact of receiving Scottish Carer's Assistance on other benefits; and to ensure there are no negative impacts on other benefits of which they are in receipt.
• Some respondents – mainly organisations – called for a co-design approach in development of Scottish Carer's Assistance and related benefits, so as to ensure processes and procedures meet the needs of carers.
• Linked to the issue of co-design, there were some requests for flexible payment procedures (weekly, monthly or bi-annual) to suit individual needs.
• Some respondents – mainly organisations – requested that the proposed future changes are introduced alongside the launch of Scottish Carer's Assistance rather than at an unspecified future date.
• Across sub-groups there were comments that eligibility for the current Carer's Allowance is too restrictive and there were requests for Scottish Carer's Assistance to be more flexible and accommodating. One example given was that payment could be made according to the number of hours spent caring, as some carers will have fluctuating caring hours.
• There were many requests for eligibility for Scottish Carer's Assistance to be extended. The most frequently cited was the inclusion of pensioners who many felt should be entitled to this benefit.
• There were also high levels of support for changes to the limitations that are currently in place as well as criticism of the current earnings threshold. Respondents would like to see carers enabled to work for a greater number of hours and for allied increases in the earnings threshold. It was suggested that this would improve household income and carer's mental wellbeing (for example, poverty and social isolation were perceived to be negative impacts of the caring role).
• Other scenarios where it was felt Scottish Carer's Assistance should offer more flexibility were where there may be more than one carer caring for a cared for person and / or a shared caring role as at present only one carer can receive the benefit.
• Across the consultation some respondents felt that all carers should qualify for the benefit, particularly as many will be caring for over 35 hours per week and making savings for the public purse.

Summary of main findings

Scottish Carer's Assistance from Launch

The consultation paper outlined a number of proposals in relation to Scottish Carer's Assistance and a majority of respondents agreed with each of these.

• When considering how Scottish Carer's Assistance services could be designed to suit carers' needs, respondents focused on a need for a choice of communication methods, straightforward processes and types of support needed by carers as well as concerns over the rules about the current Carer's Allowance (Q1).
• Respondents cited a wide range of organisations and forms of support that Scottish Carer's Assistance could link to. A key form of support was carers' centres that can provide information and local help in accessing and completing paperwork as well as performing an advocacy role (Q2).
• A majority of respondents (68%) agreed with the proposed residency criteria for Scottish Carer's Assistance. A large minority agreed that carers should need to live in Scotland or that residency should be the main consideration. Furthermore, a significant minority felt it is not possible to care for someone living outside the carer's area or a long way outside Scotland. However, there were some calls for flexibility in the arrangements, for example, when a carer close to the Scottish border provides care for a Scottish resident. Views on the 'past presence test' were mixed (Qs3-5).
• Almost three quarters of respondents agreed with the proposed redetermination timescales for Scottish Carer's Assistance. These were noted as being fair and reasonable, allowing more time to collate information and gather information and obtain support and advice. There were some comments that Social Security Scotland should not need a longer period to make a decision than carers have to request a redetermination. A small minority of respondents felt the proposed timescales were too long (Qs 6-7).
• 64% of respondents agreed with the proposals on when payments of Scottish Carer's Assistance should be suspended, with comments that the reasons given for suspension were appropriate with suspension only taking place in severe or serious circumstances. Many comments focused on the negative financial impact that stopping qualifying disability benefits can have on a carer. A large minority of respondents felt Scottish Carer's Assistance payment should continue until a person's situation is resolved, particularly as the carer will still be required to provide care (Qs 8-10).
• 67% of respondents agreed with the proposals for when an award of Scottish Carer's Assistance should be set to £0. The key reasons were that this offers a more flexible approach or it will be easier as carers will not have to reapply for their benefit (Qs 11-12).
• A large majority (85%) of respondents agreed with the proposal to pay Scottish Carer's Assistance to carers when the person they are caring for is receiving short-term assistance. The key reason for this was that the carer will still have caring responsibilities and should not be penalised financially during this process (Qs 13-15).

Extra money for carers in Scotland

• 62% of respondents agreed that Carer's Allowance Supplement should be paid alongside carers' regular payments of Scottish Carer's Assistance in future. However, a significant minority supported payment of a lump sum. There were some suggestions that carers should have a choice as to how they would like to receive this payment (Qs 16-18).
• 72% of respondents agreed with the proposed eligibility criteria for Carer's Additional Person Payment. This was felt to recognise the financial burden faced by carers and an acknowledgement of caring responsibilities. However, there was some criticism of the proposed amount of £10 per week, with suggestions that this should be increased and some disagreement with the criteria relating to a minimum of 20 hours additional care per person (Qs 19-20).
• 73% of respondents agreed with the proposed payment frequency for Carer's Additional Person Payment (Qs 21-22).
• 63% of respondents agreed with the proposal to target Carer's Additional

Person Payment to carers who are getting payments of Scottish Carer's Assistance. This was seen to be fair, sensible, logical and reasonable, though there were some calls for the payment to be made to all carers with an underlying entitlement to Scottish Carer's Assistance (Qs 23-25).

Changes to Scottish Carer's Assistance

• Almost all respondents (97%) agreed with the proposed future change to allow carers in full-time education to get Scottish Carer's Assistance. It was felt this would help to remove barriers and encourage carers to go into education. A number of benefits were highlighted including personal and professional development, career improvement, gaining of qualifications and improved mental health and wellbeing (Qs 26-27).
• A large majority (79%) of respondents agreed with the proposed future change to allow carers to add together hours spent caring for two people to reach the 35 hour caring requirement. Key was the recognition of multiple caring circumstances. A large minority felt that it is the total number of hours spent caring that is important rather than the number of people cared for. There was some concern about bureaucratic and administrative complications (Qs 28-29).
• Almost all respondents (89%) agreed with the proposed future change to continue to pay Scottish Carer's Assistance for 12 weeks after the death of a cared for person. This additional time period was perceived to allow people time to adapt to changed circumstances as well as helping to reduce financial and emotional stress (Qs 30-31).
• A similar number of respondents (87%) agreed with the proposed future change to continue to pay Scottish Carer's Assistance for 12 weeks when a cared for person goes into hospital or residential care. Respondents noted that carers will still have a caring role to fulfil and may face additional financial costs in terms of fuel, parking and other travel expenses (Qs 32-33).
• 82% of respondents agreed with the proposed future change to increase the earnings limit for Scottish Carer's Assistance. A key comment was that carers should be given the opportunity to earn more where possible as this can help to bring about financial stability and alleviate poverty as well as being beneficial to mental health and wellbeing. However, there were comments that the earnings limit should be higher than the suggested £158 per week (Qs 34-35).
• 67% of respondents agreed that the earnings threshold should be set at a level which would allow carers to work 16 hours a week alongside their caring role. While a significant minority approved of this threshold, some others commented that this limit is too low and should be increased (Qs 36-37).
• A majority (77%) of respondents agreed with the proposal to look at a 'run on' after a carer earns over the earnings limit in future. This was seen to be helpful to those with variable earnings as well as making life easier as it would help to provide some stability to carers while they adapt to changes (Qs 38-39).
• A large majority (86%) of respondents agreed that a payment for long-term carers should be considered further. This was perceived to help provide financial support and stability to carers. There were also suggestions that this payment should be available to a wider range of carers, including those in receipt of a state pension. (Qs 40-41).
• In considering what a payment should look like and who it should be for, respondents made a wide range of suggestions, although there was little consensus in what this payment should be (Q42).
• When asked to provide other views about the proposals for future changes to Scottish Carer's Assistance, most comments echoed points from earlier questions (Q43).

Impact Assessments

• Fewer than half of the respondents chose to answer any questions on impact assessments (Qs 44-48).
• In terms of those who share protected characteristics, respondents focused on women, disabled people, those within ethnic minority groups, sexual orientation and age. While views on the proposals were largely positive, it was felt that there is a need to engage with these groups and communicate with them utilising a variety of approaches.
• The key impacts on island communities were felt to be limited services available and the cost of accessing these services.
• Respondents felt that these proposals would help to reduce socioeconomic disadvantage.
• It was felt that the proposals would lead to improvements for young carers.
• There could be economic benefits both to businesses and to carer employees.