Scottish Carer's Assistance: consultation analysis

Extra money for carers in Scotland

Carer's Allowance Supplement

The consultation paper noted that Carer's Allowance Supplement is a unique payment from the Scottish Government. It is paid to carers who are receiving Carer's Allowance and living in Scotland. Payments are made by Social Security Scotland using information from the Department for Work and Pensions. It was introduced as an interim measure before Scottish Carer's Assistance replaced Carer's Allowance. It is paid every six months, in June and December, and the payment amount this financial year (2022-23) is £245.70.

The consultation set out the Scottish Government intention to continue to pay Carer's Allowance Supplement in the same way as now until the process of transferring carer's benefits from the Department for Work and Pensions to Social Security Scotland is complete. Carer's Allowance Supplement payments will remain separate from payments of Scottish Carer's Assistance. This is because Scottish Carer's Assistance is counted as income in deciding eligibility for some benefits from the Department for Work and Pensions, but Carer's Allowance Supplement is not. Payments of benefits like Universal Credit are not reduced by Carer's Allowance Supplement payments. Once all eligible carers are getting Scottish Carer's Assistance, the Scottish Government will consider how it could be paid differently.

In the future, the consultation suggested that Carer's Allowance Supplement could be paid at the same time as a carer's regular Scottish Carer's Assistance payments. Carers would get more regular payments as most carers currently receive payments weekly or every four weeks. The consultation noted that this would allow any change in circumstances to be reflected in a carer's award more quickly, and thus make over or under payments less likely. However, it also highlighted that this could be more complex for carers who need to report their income to the Department for Work and Pensions or HM Revenue & Customs. An alternative approach could be for Carer's Allowance Supplement to be paid as it is now, with payments every six months. The consultation noted that this would mean that qualifying dates would still need to be used for payments and could mean that some carers miss out on support, and some could be overpaid.

The Scottish Government proposed in the consultation that Carer's Allowance Supplement could be paid alongside carer's regular Scottish Carer's Assistance payments in future. The next questions asked:

Question 16: Do you agree or disagree that Carer's Allowance Supplement should be paid alongside carer's regular payments of Scottish Carer's Assistance in future?

Question 17: Please write the reason why you agree or disagree that Carer's Allowance Supplement should be paid alongside carer's regular payments of Scottish Carer's Assistance in future, or any other information you want to share on this question.

Question 18: Please give us any other views you want to share on the proposals for Carer's Allowance Supplement.

As outlined in table 7, 62% of respondents agreed that Carer's Allowance Supplement should be paid alongside carer's regular payments of Scottish Carer's Assistance. Among third sector (carer) organisations, local authorities and representative bodies / associations, more respondents disagreed or were unsure than agreed.

Table 7: Level of agreement that Carer's Allowance Supplement should be paid alongside carer's regular payments of Scottish Carer's Assistance in future

Q16	Number (percentage *)
	Agree	Disagree	Unsure	Not answered
Organisations (n=41)	19	6	7	9
Individuals (n=151)	87	21	30	13
Total respondents (n=192)	106	27	37	22
Total respondents answering question (n=170)	106 (62%)	27 (16%)	37 (22%)

* figures may not add to 100% due to rounding

A total of 138 respondents then provided comments in response to question 17. Of the respondents noting a preference, a significant number across all sub-groups supported a payment alongside regular payments of Scottish Carer's Assistance. Slightly fewer – although still a significant minority – noted their support for the payment of a lump sum.

Reasons for the preference for regular payments were that this is better for budgeting, that a stable income is more beneficial in the long term, or it can contribute to financial stability. Reasons for preferring a lump sum were that it is more noticeable as a sum of money when paid only twice yearly and can help with unexpected bills or can be helpful at certain times of the year such as Christmas when outgoings are higher than usual.

A few respondents – all individuals – simply noted that this supplementary payment would be very helpful.

A number of respondents who disagreed or were unsure of this proposal – mostly organisations – suggested that carers should be given the choice as to how they would like to receive this payment, with one third sector organisation noting this choice would be in line with the principles of collaboration and empowerment. Allied to this point, a few organisations commented that there is a need to consider the views of carers and utilise a co-design approach to ensure that any proposals meet the needs of recipients.

A small number of respondents – all organisations – felt that this payment should be consolidated within Scottish Carer's Assistance. A small number of respondents also felt that all carers should receive this extra payment.

Question 18 then gave respondents the opportunity to provide any other views they wanted to share on the proposals for Carer's Allowance Supplement; 82 opted to do so. Almost all the comments echoed points made at earlier questions, and these included:

• Support for this proposal.
• Positive views on this proposal demonstrating recognition of the caring role and time spent being a carer.
• This payment should be made to all carers, regardless of their earnings or being in receipt of State Pension.
• This payment should be higher.
• Preferences for payment to be made as a lump sum.
• Carers should be given the choice as to the frequency of this payment.
• This payment should be consolidated into the Scottish Carer's Assistance payment. It would help to simplify the system and administration for Social Security Scotland. However, one campaigning / advocacy organisation felt an amalgamated payment could be very confusing, given that Carer's Allowance Supplement is taxable but not taken into account when determining entitlement to benefits or tax credits.

Carer's Additional Person Payment

The consultation paper explained that the Scottish Government is committed to creating a new payment for unpaid carers in Scotland, to provide extra support for people who are getting Scottish Carer's Assistance and caring for more than one person in receipt of a qualifying disability benefit. These extra payments would be part of Scottish Carer's Assistance.

The consultation proposed that to qualify for Carer's Additional Person Payment, carers must be eligible for Scottish Carer's Assistance and receiving payments. Carers will also need to be caring for at least two people who are in receipt of a Scottish Carer's Assistance qualifying benefit. Carers would have to be providing at least 20 hours of care per week for each additional person they are applying for Carer's Additional Person Payment for, and they would have to be providing 35 hours or more of care a week for the person the carer is receiving Scottish Carer's Assistance for. They would not need to be providing this care separately from the care they provide for the person they get Scottish Carer's Assistance for – for example, many people caring for two children would be looking after both children at the same time. However, only one carer could receive Carer's Additional Person Payment for a given cared for person, as would also be the case for Scottish Carer's Assistance. The next two questions asked:

Question 19: Do you agree or disagree with the proposed eligibility criteria for Carer's Additional Person Payment?

Question 20: Please write the reason why you agree or disagree with the proposed eligibility criteria for Carer's Additional Person Payment, or any other information you want to share on this question.

As demonstrated in table 8, a majority of those answering this question (72%) supported the proposed eligibility criteria for Carer's Additional Person Payment. All health organisations and local authorities supported this proposal, although views differed across other types of organisation. None of the representative bodies / associations agreed with this proposal.

Table 8: Level of agreement with the proposed eligibility criteria for Carer's Additional Person Payment

Q19	Number (percentage *)
	Agree	Disagree	Unsure	Not answered
Organisations (n=41)	17	8	4	12
Individuals (n=151)	101	9	24	17
Total respondents (n=192)	118	17	28	29
Total responding to question (n=163)	118 (72%)	17 (10%)	28 (17%)

* figures may not add to 100% due to rounding

A total of 107 respondents then provided comments in response to question 20.

A number of key themes emerged from respondents who had agreed with the proposed eligibility criteria for Carer's Additional Person Payment. Some respondents – mostly individuals – noted that there is recognition of the financial burden faced by carers of having to care for more than one person. Others referred to this helping to make life easier. A similar number also noted that caring responsibilities need to be acknowledged and this additional payment goes some way to recognising this. There were a number of general comments that the proposal is fair, good or useful.

Among respondents who primarily disagreed with, or who were unsure about this proposal, two key themes emerged. First, and cited by a significant minority of respondents across all sub-groups, was that the amount of Carer's Additional Person Payment should be more than £10 per week, with some of these respondents referring to this payment as 'an insult' to carers that does not reflect the additional duties or responsibilities of caring for more than one person. A small number of these respondents calculated that Carer's Assistance equates to an hourly rate of £1.99 and that the Carer's Additional Person Payment equates to £0.50 per hour. It was suggested the latter should be in line with the former at the very least. As noted by a representative body / association:

"While any additional payment to carers is welcomed, the Carer's Additional Person Payment of £10 per week does not reflect the additional duties or responsibilities of caring for more than one person. [We] are concerned that this amount would not compensate for the loss of potential earnings of carers who need to give up employment because of their caring duties. As the majority of carers are women, they are disproportionately affected. This would not alleviate the financial burden carried by carers or lift many carers out of poverty. Where a carer is in receipt of Universal Credit the additional amount would be deducted from UC and there would be no financial gain to carers."

A third sector organisation involved in offering care to people at end of life commented:

"The Carer's Additional Person Payment must be doubled to £20 per additional person to help support the carer with the cost of living and costs associated with caring for someone with a terminal illness, such as medicines, food, energy and home adaptations, otherwise families are at risk of poverty at the end of life."

Secondly, and corresponding with comments that an additional payment of £10 is insufficient, a significant minority of respondents – mostly organisations who disagreed at question 19 – disagreed with the criteria relating to a minimum of 20 hours additional care per person. It was felt that this does not take into account the extent and complexity of care provision to multiple people with different needs and circumstances. A third sector organisation suggested this payment should be more flexible and responsive to individual needs and requirements. A health organisation felt the additional payment should be increased or the hours enabling eligibility should be decreased.

A few respondents – mostly organisations – felt the list of criteria was too long, with one organisation in the third sector commenting that it is unfair that those with an underlying entitlement (carers who are eligible for Scottish Carer's Assistance but who receive another benefit instead, including State Pension) will not receive this payment. A representative body / association suggested that there is a need for more evidence to justify the proposed eligibility criteria.

A small minority of respondents – who mostly disagreed or were unsure about the proposal - outlined various concerns or queries. These included:

• There is a need to consider the link between the Carer's Additional Person Payment and other benefits.
• All carers with an underlying entitlement should receive this allowance and this discriminates against people who receive certain benefits which make them ineligible.
• There is a need to consider instances where caring is split between two partners, but only one qualifies for Carer's Allowance and the associated national insurance credit.
• Tax credits should be offered to families with one earner and an unpaid carer.
• Carer's Allowance should not be classed as additional income or taxed.
• The impact of the Additional Person Payment upon Severe Disability Premium (SDP) should be considered, as currently those receiving care become ineligible for SDP where Carer's Allowance is paid.

Carer's Additional Person Payment

The amount and frequency of payments

The consultation paper outlined that the payment would be the equivalent of £10 per week and would be up-rated each year using the same measure of increases in costs that are used for other Scottish benefits. It proposed that the Carer's Additional Person Payment would be paid at the same time as Scottish Carer's Assistance payments. Most carers currently get Carer's Allowance payments either weekly or every four weeks. The next two questions asked:

Question 21: Do you agree or disagree with the proposed payment frequency for Carer's Additional Person Payment?

Question 22: Please write the reason why you agree or disagree with the proposed payment frequency for Carer's Additional Person Payment, or any other information you want to share on this question.

As noted in the following table, once again, a majority of those answering this question (73%) agreed with the proposed payment frequency for Carer's Additional Person Payment. All health organisations and local authorities agreed with this proposal.

Table 9: Level of agreement with the proposed payment frequency for Carer's Additional Person Payment

Q21	Number (percentage *)
	Agree	Disagree	Unsure	Not answered
Organisations (n=41)	21	3	6	11
Individuals (n=151)	96	9	26	20
Total respondents (n=192)	117	12	32	31
Total responding to question (n=161)	117 (73%)	12 (7%)	32 (20%)

* figures may not add to 100% due to rounding

A total of 64 respondents then provided comments in response to question 22.

A number of key themes emerged, most of which were cited by less than 10 respondents and most of whom echoed points made in the consultation paper.

The key theme, noted by a significant minority, was that it should be paid alongside their regular payment, with some of these respondents noting that it would keep things simple. A small minority of respondents simply noted that this proposal makes sense. A few organisations commented that this will be good for budgeting purposes, as respondents will know the amount of money they will be receiving regularly. There were also a few comments that this would provide financial stability for carers. Other benefits noted by small numbers of respondents were that this proposal would:

• Reduce administration costs.
• Help to avoid confusion.
• Help to avoid underpayments or overpayments.
• Avoid the need for qualifying dates that are associated with lump sum payments and clear any confusion over cut-off dates in reporting changes in circumstances.

The issue of choice for the carer was raised by a few organisations who answered 'unsure' to question 21. These felt that carers should be offered a choice as to when they would like to receive this payment, to reflect their individual circumstances. Allied to this point, a small number of organisations also commented that the approach should be co-designed with carers and their representative organisations. One local authority was concerned that this could be difficult to manage, and that the payment might be taxable.

Targeting Carer's Additional Person Payment at carers getting Scottish Carer's Assistance

The consultation explained that Carer's Additional Person Payment will be paid to people in receipt of Scottish Carer's Assistance and caring for more than one person who is getting a disability payment. This means it would not be paid to people who have 'underlying entitlement' to Scottish Carer's Assistance, or who get the Universal Credit Carer Element instead. This is how Carer's Allowance Supplement works now. The consultation also explained that the reason that Carer's Allowance Supplement and Carer's Additional Person Payment are targeted at people getting payments of Scottish Carer's Assistance is that 'overlapping benefits' are paid at a higher rate, and people getting Universal Credit Carer Element can receive Carer's Allowance unless they are earning over the earnings limit. This means that carers receiving payments of Scottish Carer's Assistance are likely to be on lower incomes. The next three questions asked:

Question 23: Do you agree or disagree with the proposal to target Carer's Additional Person Payment to carers who are getting payments of Scottish Carer's Assistance?

Question 24: Please write the reason why you agree or disagree with the proposal to target Carer's Additional Person Payment to carers who are getting payments of Scottish Carer's Assistance, or any other information you want to share on this question.

Question 25: Please give us any other views you want to share about the proposed Carer's Additional Person Payment.

As noted in the following table, once again, a majority of those answering this question (63%) agreed with the proposal to target Carer's Additional Person Payment to carers who are getting payments of Scottish Carer's Assistance.

Table 10: Level of agreement with the proposal to target Carer's Additional Person Payment to carers who are getting payments of Scottish Carer's Assistance

Q23	Number (percentage *)
	Agree	Disagree	Unsure	Not answered
Organisations (n=41)	15	10	6	10
Individuals (n=151)	85	12	31	23
Total respondents (n=192)	100	22	37	33
Total responding to question (n=159)	100 (63%)	22 (14%)	37 (23%)

* figures may not add to 100% due to rounding

A total of 72 respondents then provided comments in response to question 24. A significant minority of these simply noted their support for the proposal without providing much by way of detail. The proposal was regarded as being fair, sensible, logical and reasonable or that people caring for more than one person should receive more support.

A key theme which emerged, primarily from those who disagreed with this proposal, and cited by respondents across most sub-groups, was that Carer's Additional Person Payment should be paid to all carers with an underlying entitlement to Scottish Carer's Assistance. A campaigning / advocacy organisation remarked:

"The consultation does not explain the rationale for restricting this additional payment to those eligible for a financial award for Scottish Carer's Assistance. We believe that Scottish Government should investigate the potential for eligibility to be broadened to all with an entitlement to Scottish Carer's Assistance, as it appears to us that it could be decoupled from the underlying entitlement issues with other DWP benefits. It is important to recognise the complexity of some people's caring responsibilities."

This was backed up by another campaigning / advocacy organisation, which suggested:

"A solution would be to pay Carer's Additional Person Payment to carers who have an underlying entitlement to carers allowance as well. This would be in line with the policy intent, which is not to fully mitigate the costs of caring, nor to pay them for their carers role – its role is to provide support for carers. [We] recognise that 'having more than one caring role can have a bigger impact on carers' health and wellbeing' – so carers on overlapping benefits equally need this support."

A few organisations outlined concerns that:

• Some individuals could be financially worse off as a result of applying for new Scottish benefits.
• This should be considered for those who receive only the Carer Element of Universal Credit (UC) as UC recipients are often no better off than the Scottish Carer's Assistance recipient.

The need for Social Security Scotland to work alongside the Department for Work and Pensions was highlighted by a small number of organisations. The benefits to this were that it would help to minimise any financial penalties for overlapping benefits. One campaigning / advocacy organisation felt there should be a data sharing agreement between Social Security Scotland and the Department for Work and Pensions to identify carers on Universal Credit who may be entitled to additional support.

A few organisations welcomed the communications strategy outlined in the consultation paper, although they felt that carers would need to be supported with appropriate independent advice. A campaigning / advocacy organisation suggested a referral protocol, and a health organisation felt that carers should be able to seek advice from an advisor within Social Security Scotland advocacy services.

A total of 57 respondents provided comments in response to question 25, many of which mirrored comments made to question 24. A number of these respondents noted their support for this proposal, although there were a few provisos around other social security benefits and a desire that this payment should not result in carers losing income from elsewhere. A few respondents were also positive that this provides recognition for carers, although a small number also commented that this was long overdue.

A large minority of respondents commented that an additional payment of £10 is too low and does not reflect the potential volume of care being provided, with a few respondents suggesting alternative payments. These included a payment at the same rate as a single person who is cared for but with a sliding scale, relating to the hours of care provided. One third sector organisation commented:

"While £10 per person is a progressive policy in comparison with decades of DWP neglect, the amount proposed is considerably lower than other policy positions that could have been taken. It would be far better if carers could be effectively paid minimum wage for the 20 hours worked, with the same paid again for every additional qualifying cared for person. The net expenditure of this as compared with the savings made against the health and social care budgets and as compared with potential reduction in other entitlements (e.g., severe disability premiums) would still represent extremely good value."

There were also some repeated calls for this payment to be paid to all carers, including those in receipt of a state pension.