Scottish Carer's Assistance: consultation analysis

Changes to Scottish Carer's Assistance

The consultation paper explained that when Scottish Carer's Assistance is first launched, many of the eligibility criteria will be kept the same as it is now. The Scottish Government noted, this is intended to avoid a 'two-tier system' where carers already getting Carer's Allowance are treated differently from people who have newly applied for Scottish Carer's Assistance. Longer term, it is planned that further changes may be introduced. The priority changes proposed in the consultation paper are:

• Removing the education restrictions so full time students can receive Scottish Carer's Assistance.
• Allowing carers to add together hours spent caring for more than one person.
• Increasing the time carers will receive Scottish Carer's Assistance from eight to twelve weeks after the death of a cared for person.
• Extending the period of payment when a cared for person goes into hospital or residential care from four to twelve weeks.
• Increasing the earnings limit so carers can earn more and still get financial support and addressing the cliff-edge

Access to education and training

The Scottish Government is proposing to remove the current education restriction. The next two questions asked:

Question 26: Do you agree or disagree with the proposed future change to allow carers in full-time education to get Scottish Carer's Assistance?

Question 27: Please write the reason why you agree or disagree with the proposed future change to allow carers in full-time education to get Scottish Carer's Assistance, or any other information you want to share on this question.

As noted in table 11, almost all those answering this question (97%) agreed with the proposed future change to allow carers in full-time education to get Scottish Carer's Assistance.

Table 11: Level of agreement with the proposed future change to allow carers in full-time education to get Scottish Carer's Assistance

Q26	Number (percentage *)
	Agree	Disagree	Unsure	Not answered
Organisations (n=41)	33	1	-	7
Individuals (n=151)	125	1	3	22
Total respondents (n=192)	158	2	3	29
Total answering question (n=163)	158 (97%)	2 (1%)	3 (2%)

* figures may not add to 100% due to rounding

A total of 132 respondents made comments at question 27, almost all of these were positive. The largest proportion – one in two respondents – predicted that the change would help encourage more carers to go into education, saying it would reduce barriers and allow people to study while caring. Large minorities agreed the change was a fair and sensible approach, and that carers deserve extra help and recognition without being penalised for having an education. A significant minority thought that carers financial strains would be eased and that they would no longer be put off education by the thought of losing Carer's Allowance. A third sector (carer) organisation noted that many students drop out of education due to financial issues.

Similar numbers thought the change was advantageous, making it easier to study whilst caring. Points were made about it being possible to both study and care full-time, though this would make it very difficult to take on part-time work as well. Scottish Carer's Assistance could therefore supplement student incomes.

The benefits of education for carers were highlighted by a large minority of respondents, in terms of personal and professional development, career improvement, gaining new qualifications, helping with wellbeing and mental health and creating more opportunities. A significant minority felt education would improve future prospects for carers when they are no longer in a caring role and that they would be better prepared for employment or career changes. A significant minority specified the benefits for young carers as they would not be excluded from higher education and future opportunities would be improved.

A few respondents urged the proposed change to take place when the benefit is launch, or at least with a given timescale for implementation, rather than at an unspecified future date. Very small numbers of respondents voiced the following other thoughts:

• The change would allow students to be awarded financial support while being a recognised as a carer.
• There is a need to ensure that students getting student financial support are better off overall from being able to receive Scottish Carer's Assistance

(e.g. Scottish Carer's Assistance should not be considered as income for student financial support or funding assessment calculations, and vice versa).

• Education could provide more opportunities for carers to learn or educate themselves about the conditions or disabilities they are caring for.
• The change could benefit women, reflecting that in society caring roles most typically fall to women, and unpaid care can act as a barrier to education.

The only negative note was from a health organisation which viewed it as impossible to fit in full-time study and full-time caring without having the carers health and wellbeing affected, therefore advised safeguards to be put in place. However a few respondents also noted that many courses were now very flexible, being delivered in a hybrid fashion or online, thereby affording increased opportunities for carers to fit them in with their caring duties.

Recognising different caring situations

The consultation paper explained that Carer's Allowance is only paid where 35 hours or more of care is provided each week by one person, for one person. This means that where someone is caring 35 hours or more every week but this care is split across two or more people, they are not eligible to get the benefit. The Scottish Government is proposing to allow carers to add together hours spent caring for two people to reach the 35 hours per week caring requirement. Questions 28 and 29 asked:

Question 28: Do you agree or disagree with the proposed future change to allow carers to add together hours spent caring for two people to reach the 35 hour caring requirement?

Question 29: Please write the reason why you agree or disagree with the proposed future change to allow carers to add together hours spent caring for two people to reach the 35 hour caring requirement, or any other information you want to share on this question.

As noted in the following table, a large majority (79%) of those answering this question 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 (130 agreed and only six disagreed, although 28 gave an answer of 'unsure').

Table 12: Level of agreement with the proposed future change to allow carers to add together hours spent caring for two people to reach the 35 hour caring requirement

Q28	Number (percentage *)
	Agree	Disagree	Unsure	Not answered
Organisations (n=41)	29	-	3	9
Individuals (n=151)	101	6	25	19
Total respondents (n=192)	130	6	28	28
Total answering question (n=164)	130 (79%)	6 (4%)	28 (17%)

* figures may not add to 100% due to rounding

A total of 110 respondents provided further comments. A very large majority of comments were positive about the proposed change. A large minority said it recognised multiple caring circumstances and that many carers care for more than one person. Scenarios where the change would be beneficial included care of parents, sandwich carers (i.e. carers of parents and children simultaneously) and situations where cared for people do not live in the same home. A small number of respondents foresaw that the number of people caring for more than one person was increasing or likely to increase.

A large minority reiterated that entitlement should be dependent on the total amount of caring, and that it was the total number of hours that was important rather than the number of people cared for. Similar numbers cited general agreement with the proposal, saying it seemed fair, sensible or a positive step, with a few respondents stating this would rectify a longstanding inequity in Carer's Allowance. A significant minority were in favour of having more flexibility in meeting Scottish Carer's Assistance eligibility requirements, saying that the system should be more reflective of individual needs and should incorporate more than two carers.

A few respondents (mainly campaigning / advocacy organisations) urged that consideration should be given to including all the hours of those who care for more than two people. It was hypothesised that these carers were likely to be most vulnerable to poverty, having less time available for work and potentially higher travel costs to reach those they care for. A campaigning / advocacy organisation noted:

"We recognise that this potentially makes the claims process and change of circumstances notifications more complicated, however, we note that the process for claiming in relation to two or three people is in existence for the Young Carer's Grant (albeit for over 16 hours per week)."

A few respondents recommended alternative payment rules, reasoning that carers for more than one person should get paid more than single person Carer's Assistance because of greater impacts and because these carers do far more than 35 hours per week of caring. Suggestions were made for a sliding scale or payment based on each hour of care. More generally, there were a couple of suggestions from a representative body and a third sector organisation to reduce the qualifying number of hours from 35 per week.

The most frequently mentioned concerns about the proposal were bureaucratic and administrative complications. These included having to deal with potential multiple applications and whether or not several people helping with care could have several applications regarding one persons care. Also mentioned were differing numbers of hours per week of care depending on individual circumstances and caring requirements, change of circumstances notifications and difficulties combining and counting hours of care.

Small numbers of respondents voiced concerns about possible impacts on other benefits and rights (e.g. the cared for persons reserved benefits, risks to the rights of a second carer who may also be adding together hours to reach the 35 hour threshold). There were also a small number of misconceptions regarding care being classified as a job with the carer being deemed ineligible for Universal Credit benefits, when in fact Scottish Carer's Assistance is an income replacement benefit which can bring carers into entitlement for Universal Credit. Additionally, very small numbers of respondents were worried that there could be a rise in fraudulent applications and abuse of the system.

More stable support where life events have affected the cared for person

When a cared for person dies

The consultation paper noted that Carer's Allowance is paid where the person being cared for is getting certain disability benefits which means that payments will stop when the cared for persons benefits stop. The consultation explained that when a cared for adult goes into hospital, Carer's Allowance will stop after four weeks. When a cared for person dies, Carer's Allowance payments stop after eight weeks. However, the Scottish Government noted in the consultation that it recognises that changes in a cared for persons disability benefits do not always match the needs of the carer and that unpaid carers need more stable incomes.

As such, the Scottish Government is planning to extend the period of Scottish Carer's Assistance so that it is paid for twelve weeks after the death of a cared for person.

Questions 30 and 31 asked:

Question 30: Do you agree or disagree with the proposed future change to continue to pay Scottish Carer's Assistance for 12 weeks (rather than 8 weeks) after the death of a cared for person?

Question 31: Please write the reason why you agree or disagree with the proposed future change to continue to pay Scottish Carer's Assistance for 12 weeks (rather than 8 weeks) after the death of a cared for person, or any other information you want to share on this question.

As noted in Table 13, almost all of those answering this question (89%) agreed with this proposed future change. Only one campaigning / advocacy organisation disagreed with this proposed future change.

Table 13: Level of agreement with the proposed future change to continue to pay Scottish Carer's Assistance for 12 weeks (rather than 8 weeks) after the death of a cared for person

Q30	Number (percentage *)
	Agree	Disagree	Unsure	Not answered
Organisations (n=41)	30	1	2	8
Individuals (n=151)	112	6	9	24
Total respondents (n=192)	142	7	11	32
Total responding to question (n=160)	142 (89%)	7 (4%)	11 (7%)

* figures may not add to 100% due to rounding

A total of 120 respondents made comments in support of their initial response to this question. A large number of these echoed points covered in the consultation paper. A significant minority reiterated their support for the proposal without further detail and a small minority noted this is a more empathetic and compassionate approach than at present. A campaigning / advocacy organisation acknowledged:

"Cared for people are often loved ones; spouses, children, close family or friends. The death of a loved one can be traumatic. This can be more so for the death of a cared for person. Caring for a person can change the relationship you have with this person, bringing you closer than ever. Moreover, caring can also have a significant impact on a carers life. Becoming a carer can impact employment, relationships with other people and a persons sense of self. When a cared for person dies, carers are not only faced with the death of a loved one, but a complete change in their life. The transition from being a full-time carer can have huge impacts on a person. Eight weeks is not likely to be enough time to fully cope with the death of a loved one. By extending the payments, it will allow the carermore time to come to terms with the death, the impact this will have on their life, and time to secure a stable income. Extending the time to 12 weeks is a small, but an impactful way of providing additional support to carers."

A key theme cited by almost half of respondents was that the proposed extension period would allow people time to adapt to their changed circumstances and can be used as a buffer where carers can sort out their benefits, look for employment or have some time to grieve before there are changes to their financial circumstances. A significant minority of respondents also noted that this extended period would help to reduce financial and emotional stress at a time of significant change. A few respondents noted that while a carers grief may be similar to that of someone else who has suffered a loss, carers have less practical ability to get back into work or education or to rebuild support networks.

Accessing advice and support was seen to be important to a few respondents, mostly organisations. There were suggestions of a need for carers to be able to access help across a range of areas including financial support, legal aid, information on other benefits and access to advisors.

While respondents generally welcomed this proposal, a small minority of respondents who both agreed and disagreed felt that the Scottish Government should introduce a longer time period. There were suggestions for this to be extended from between 16 weeks to 12 months, although there was no consensus on this time period. A Third Sector (Carer) organisation quoted from an unpaid carer who noted:

"Because Carer's Allowance doesn't let many carers work or study while being a carer, they are often stuck in a poverty trap where they have very limited ability to earn. Then when the cared for person dies, goes into a home, etc - the carer may well be unemployable. The household income will have disappeared and there are also all the emotional consequences to consider! In many cases it's very likely there has been a huge emotional impact from the bereavement of the stress of change of circumstances."

Another Third Sector organisation suggested that the period of 12 weeks should be extended where there are extenuating circumstances.

A small number of individuals who disagreed with this proposal felt that 8 weeks is enough time for a carer to sort out the necessary legalities of the cared for persons estate.

Finally, in response to this question, a Third Sector organisation and a campaigning / advocacy organisation suggested the Scottish Government should introduce a "Post Caring Support Payment"at the same level as Jobseeker's Allowance, which would be linked to the length of time of being a carer. They also felt that there should be a new fund to support the training and education of carers returning to work or seeking employment for the first time.

When a cared for person goes into hospital or residential care

The Scottish Government is also proposing to extend the period of payment when a cared for adult goes into hospital or residential care from four to twelve weeks. Questions 32 and 33 asked:

Question 32: Do you agree or disagree 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?

Question 33: Please write the reason why you agree or disagree 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, or any other information you want to share on this question.

As noted in the following table, 87% of those answering this question agreed with this proposed future change. All local authorities, representative bodies / associations and health organisations agreed with this proposal. Only two third-sector organisations disagreed with this proposed future change.

Table 14: Level of agreement 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

Q32	Number (percentage *)
	Agree	Disagree	Unsure	Not answered
Organisations (n=41)	29	2	2	8
Individuals (n=151)	108	6	11	26
Total respondents (n=192)	137	8	13	34
Total respondents answering question (n=158)	137 (87%)	8 (5%)	13 (8%)

* figures may not add to 100% due to rounding

In response to Question 33, a total of 110 respondents provided comments. A number of these welcomed this proposal, with some comments that this is an emotionally challenging time for both carers and the cared for person and that this offers a more compassionate approach. A small number of organisations commented that the current limit of four weeks is unreasonable.

The key theme to emerge from a significant minority of respondents of all types was that these carers still have a caring role to fulfil. This may include sorting out paperwork, carrying out tasks relating to medication, carrying out housework, contacting other family members and providing emotional support to the cared for person while they are in hospital or residential care. One campaigning / advocacy organisation noted that the caring role can become more intense as the carer may need to advocate for the cared for person. As noted by a representative body:

"While someone is in hospital or temporary care their carer is unlikely to be relieved of all caring responsibilities. They will have a different set of responsibilities and will still require to provide support and assistance during this time. The nature of the support will change but nonetheless they will still be actively involved in caring for the person and meeting their needs both on a practical and emotional level. Carers are actively encouraged to support their loved one when in hospital or care, especially where their needs are complex or they have communication difficulties. Carers cannot be asked to contribute in this way and lose access to their Carer's Allowance where it assumed they are no longer carrying out caring duties. This also assumes that, for the period a person is in hospital, their carer can go and find work or will apply for other benefits thereby creating a more complex benefits system than is necessary."

A small minority of respondents also noted that many carers will face additional financial costs when visiting the cared for person. These include the costs of parking, fuel and other travel expenses.

Small numbers of respondents also noted that carers need this payment to be continued as it is needed for living expenses and that it helps with their financial commitments, or that carers need continuity of payments to provide them with some form of financial stability when a cared for person goes into hospital or residential care.

Time to adjust to changed circumstances was outlined by a small minority of respondents across most sub-groups. It was felt that this increased time period allows longer for a carer to adjust to their changed circumstances and to sort out their (and the cared for person's) finances. Furthermore, it offers more time for carers who need to enter the employment market for the first time or to re-enter this after a period of caring. This extension also allows time for an accurate assessment of the likelihood of the cared for person remaining in hospital or residential care.

A few respondents, mainly organisations – noted that the reapplication process can be problematic and that this proposal helps to reduce paperwork for all concerned as well as removing the worry of having payments stopped and then restarting. One individual commented that the reapplication process can take up to 12 weeks.

The issue of finding temporary employment for a period of only 12 weeks was identified as problematic for carers, particularly when they still have a caring role to undertake.

While this proposed extended period was welcomed by many of these respondents, a small number felt that the 12 week period is not long enough, with some comments that this should be extended for the duration of the hospital or residential care admission. Linked to this, there were also some specific comments on issues related to hospital discharge in that this can be a lengthy process, particularly if there are changes to a care package, and this can penalise carers despite the discharge process being out-with their control. A few organisations suggested that there should be an element of discretion to allow for special circumstances, for example, so a carer would receive payment for longer if there is a delay to hospital discharge but it is not the fault of the carer.

While most respondents were positive about this proposal, a small number of individuals noted that 12 weeks is too long a time to pay this benefit. While there was no consensus about what time period is most appropriate, there were references to four weeks and eight weeks. One respondent felt that the payment should be stopped after a shorter period for carers of those going into residential care as their chances of returning home would be minimal.

Access to paid work

The consultation paper noted that carers earning £128 per week or more (the 2021/22 rate in place at the time of the consultation), after deductions for things like pension contributions, cannot receive Carer's Allowance. Additionally if a carer earns £1 over this limit, they lose the whole Carer's Allowance award (often referred to as the earnings 'cliff edge'). The Scottish Government is proposing increasing the earnings threshold, which would increase the amount carers could earn while receiving Scottish Carer's Assistance. The formula for this could be linked to 16 hours at a specific rate, such as the Real Living Wage^[1]. This would equate to an earnings level of around £158 weekly. As reporting earnings is already a requirement for Carer's Allowance, the consultation noted that this change should not make the system more complicated for carers. Questions 34-37 asked:

Question 34: Do you agree or disagree with the proposed future change to increase the earnings limit for Scottish Carer's Assistance?

Question 35: Please write the reason why you agree or disagree with the proposed future change to increase the earnings limit for Scottish Carer's Assistance, or any other information you want to share on this question.

Question 36: Do you agree or disagree that the earnings threshold should be set at a level which would allow carers to work 16 hours a week alongside their caring role?

Question 37: Please write the reason why you agree or disagree that the earnings threshold should be set at a level which would allow carers to work 16 hours a week alongside their caring role, or any other information you want to share on this question.

Proposed future change to increase the earnings limit for Scottish Carer's Assistance

A majority of respondents (82%) agreed with this proposal. Across organisation sub-groups, all local authorities and representative bodies / associations agreed with this proposal. Only one third sector organisation disagreed.

Table 15: Level of agreement with the proposed future change to increase the earnings limit for Scottish Carer's Assistance

Q34	Number (percentage *)
	Agree	Disagree	Unsure	Not answered
Organisations (n=41)	30	1	-	10
Individuals (n=151)	107	14	15	15
Total respondents (192)	137	15	15	25
Total respondents answering question (n=167)	137 (82%)	15 (9%)	15 (9%)

* figures may not add to 100% due to rounding

A total of 132 respondents chose to comment at question 35. A large minority, one in three perceived that carers should not be penalised or deterred from working, and that they should be given the opportunity to earn more where possible. Points were made about it being difficult to live off Carer's Allowance by itself and working being an aid to financial stability and alleviating poverty. A significant minority added that it was good for carers to work, giving them a life alongside caring, being beneficial for mental health and being an aid to securing employment at the end of their caring role.

A large minority from all sub-groups agreed that the current earnings limit of £128 per week was too low and were in favour of it being raised. These respondents regarded this limit as acting as a disincentive to work, not allowing for having a part time job at the living wage and making re-entry to the workplace difficult. However, a significant minority advocated raising the earnings limit further than the suggested £158 per week, regarding this amount as still too low to make a difference as it restricts carers to working in the lowest paid roles and offers limited career progression. There were also a few complaints that the amount discriminated against better-paid carers (e.g. those earning above the Real Living Wage). A typical comment was as follows:

"I agree because at present my husband is having to try and find a job that only lets him work around 8 hours a week. He wants to work part-time but because of the cap on earnings, he can't even get a 16 hrs a week job. It's ridiculous." (Individual)

A few respondents each advocated for the earnings limit to increase with rising wages (either living or minimum) or for it to rise in line with increased living costs, taking into account additional expenditure incurred through caring such as special diets, equipment and heating.

A significant minority of respondents viewed a 'cliff edge' approach as being unfair, noting that being £1 over the threshold stops entitlement to Carer's Allowance. Alternative recommendations were made for a tapered approach or sliding scale for income above the earnings limit in order to reduce awards rather than stop them entirely.

Slightly higher numbers of respondents reinforced the aforementioned negative views of the earnings limit, claiming a lack of fairness in that too many carers miss out on Carer's Allowance because they earn over the current limit. Raising the limit was looked upon favourably, reasoning that this would improve recognition for carers, open up Scottish Carer's Assistance to more carers and result in fewer people leaving employment or reducing their hours, with consequential benefits for employers. A few respondents viewed the new approach as fair and sensible.

A small minority mistakenly perceived that the current Carer's Allowance system fails to take variable work patterns or variable income (e.g. through self-employment or zero hour's contracts) into account, whereas in actual fact earnings can be averaged where a clear work pattern can be identified. However, two individual respondents gave examples of Covid-related or Christmas bonuses causing problems with the cliff edge to the extent that they had asked not to receive these due to fears of losing Carer's Allowance. There were therefore requests to average out earnings in any new Scottish Carer's Assistance system.

A significant minority, including a majority of the small number who disagreed with the proposed future change to increase the earnings limit for Scottish Carer's Assistance, argued that entitlements should be based solely on the hours spent caring, and that limits on earnings or hours worked should not matter and be removed. It was reasoned that this should be deserved because carers save money on social care.

Only a small number of respondents explicitly stated that they preferred the suggestion of using a formula based on 16 times the hourly Real Living Wage (£158). Amongst these, it was foreseen that this limit would let carers know easily what they can earn up to, as well as providing more flexibility for working carers. Similar numbers however advocated against this approach, stating that it was often the case that it was necessary to work more hours than these in order to retain a job. A few respondents noted that parents with cared for children attending school find it easier to do more hours of work but are denied entitlements. Very small numbers of respondents stated a preference for limiting hours rather than limiting the amount earned.

Concerns were raised by a few respondents about the knock-on effects of increasing the earnings limits for Scottish Carer's Assistance on other benefit entitlements.

Views on the earnings threshold

A majority of respondents (67%) 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.

Table 16: Level of agreement that the earnings threshold should be set at a level which would allow carers to work 16 hours a week alongside their caring role

Q36	Number (percentage *)
	Agree	Disagree	Unsure	Not answered
Organisations (n=41)	25	2	4	10
Individuals (n=151)	86	25	24	16
Total respondents (n=192)	111	27	28	26
Total respondents answering question (n=166)	111 (67%)	27 (16%)	28 (17%)

* figures may not add to 100% due to rounding

A total of 129 respondents then commented at question 37. Overall, there was a fairly even split between those respondents who thought a 16 hour limit was about the right amount and those who desired higher limits or more flexibility with Scottish Carer's Assistance.

The highest numbers (a large minority) thought that a 16 hour limit was too low and should be increased. A variety of reasons were offered for this, including consideration of cost of living increases, a lack of feasibility in holding management or other well paid roles in a 16 hour week, a lack of jobs allowing as few as a 16 hour week, the amount being an insufficient increase to help support carers to escape the poverty trap, and an increase should be allowed if pay was at minimum wage levels, rather than living wage levels. A few respondents suggested alternative hourly limits, with 20 hours mentioned most frequently, although levels of 24, 25, and 30 hours were also recommended.

A few respondents wished to see the threshold scrapped entirely, perceiving that online workers can work while combining caring roles or that if carers were caring full-time they would be unable to work many hours anyway. A similar number reiterated that Scottish Carer's Assistance entitlements should simply depend on the number of hours of care given, regardless of hours worked or earnings, urging for carers to be recognised for their roles in enabling savings to be made in social care.

A significant minority, including one in three organisations, foresaw a need to allow or account for higher pay rates (than minimum or living wage) alongside the hourly threshold, perceiving a need for the earnings threshold to be raised. Issues were noted around carers being stopped from working a significant number of hours if they were on a high rate of pay as Scottish Carer's Assistance support would then be jeopardised, and a need to compensate carers for significant additional costs incurred in caring (e.g. heating, equipment). One suggestion was for the hourly limit to be based on average hourly wages rather than the Real Living Wage. There were a small number of calls for good information and communication to be given to carers about the impact of fiscal boundaries set by the hourly and earnings limits on eligibility for Scottish Carer's Assistance. A small number of respondents advocated for there to be no limit on earnings (i.e. an ability to work up to 16 hours per week irrespective of the hourly rate of pay).

A significant minority, however, viewed the 16 hour threshold as being the right amount, with around half of these specifically mentioning 16 hours at a living wage level of pay. Comments suggested that this proposal was realistic, fair and workable amid negative comments about the current Carer's

Allowance limit (e.g. difficulties incurred in trying to work and care at the same time). While also approving of the 16 hour limit, a small minority saw this as merely a step in the right direction or a bare minimum requirement, which will need to be reviewed over time.

A significant number each noted the following positive knock-on effects:

• It would help provide carers with respite and relief from stress (e.g. advantageous for mental health, helping to sustain the caring role and helping to prepare the carer for life when a caring role ends).
• It would allow more carers to care and work (e.g. while children in education are at school).
• It would give carers extra income with subsequent fewer financial worries.

In contrast to a point made above about jobs being difficult to access at a limit of 16 hours per week, a few respondents regarded this figure as amounting to standard hours for a part time job, approving of the greater choice available compared with the current situation. A couple of respondents noted that a 16 hour threshold aligns with the ability to receive Working Tax Credits.

A small minority cited concerns over the enabling of working 16 hours a week in addition to 35 hours (or more) caring causing burnout amongst carers amid doubts over whether carers would be able to spend such a time away from their responsibilities. A representative body noted:

"… 81% of adult carers caring for 35+ hours per week are already caring for 50+ hours a week; although these figures would need reanalysis for working age carers, they do indicate that many claimants of the Scottish Carers Assistance will not have any time for part-time work, unless the 35+ caring hour eligibility threshold is itself reduced."

Again, there were concerns from a few respondents regarding the treatment of fluctuating earnings and/or hours worked. Very small numbers of respondents reiterated opposition to a 'cliff edge' situation resulting in additional hours worked failing to make up for the loss of a Scottish Carer's Assistance award. Similar numbers had concerns about the impact of the proposal on benefits such as Tax Credits, Universal Credit and Severe Disability Premiums amid requests for advice on this issue.

Addressing the 'cliff edge'

The consultation paper further proposed replacing the 'cliff edge' with a 'run on' period. Payments could continue for a number of weeks after a carer earns over the earnings limit, which would provide more stability. Support could also be reduced gradually so carers would have more time to adjust before their Scottish Carer's Assistance ends. The consultation noted this would also help carers who have fluctuating earnings. An 'earnings taper' option was also suggested which would mean payments of Scottish Carer's Assistance would continue when a carer earned more than the limit but would be reduced as earnings increased. This is similar to how Universal Credit works. The Scottish Government found the run on option would be a better way to fix the cliff edge issue for a number of reasons. The consultation noted that an earnings taper could introduce more interactions with the tax system and could result in making the benefit much more complicated, particularly for carers getting other financial support. The Scottish Government also looked at an option to remove the earnings limit and replace it with a limit on the hours per week carers could work, which would allow unpaid carers to take on higher paying jobs and earn more while working part-time. However, the consultation noted that this would need a new system to be created and could make the benefit more complicated. With these issues in mind, the Scottish Government proposed the introduction of a run on period after earnings have exceeded the earnings threshold.

Questions 38 and 39 asked:

Question 38: Do you agree or disagree with the proposal to look at a 'run on' after a carer earns over the earnings limit in future?

Question 39: Please write the reason why you agree or disagree with the proposal to look at a 'run on' after a carer earns over the earnings limit in future, or any other information you want to share on this question.

As noted in table 17, 77% of those answering this question agreed with the proposal to look at a 'run on' after a carer earns over the earnings limit in future

Table 17: Level of agreement with the proposal to look at a 'run on' after a carer earns over the earnings limit in future

Q38	Number (percentage *)
	Agree	Disagree	Unsure	Not answered
Organisations (n=41)	26	-	5	10
Individuals (n=151)	98	10	23	20
Total respondents (n=192)	124	10	28	30
Total respondents answering question (n=162)	124 (77%)	10 (6%)	28 (17%)

* figures may not add to 100% due to rounding

A total of 106 respondents chose to answer question 39. There were two dominant themes, each noted by large minorities as outlined below.

Firstly, it was suggested that a 'run on' would be helpful for those with variable earnings as it was perceived that these carers would no longer have their award ended if they were temporarily over the earnings limit. Carers in situations involving zero hours contracts, overtime pay, bonuses, seasonal work and fixed term contracts were specified in this respect as beneficiaries.

Secondly, it was perceived that a 'run on' would make life easier for carers by way of provision of stability while they adapted to changes, particularly by way of less stress and worry over finances and mitigation of damage caused by 'cliff edge' situations. A few respondents noted this would particularly help carers receiving pay rises, which would currently take them over the earnings limit.

A significant minority of respondents made general comments in favour of the 'run on' approach, stating it seemed reasonable, pragmatic and fair compared with the current Department for Work and Pensions system. Similar numbers signalled their opposition to a 'cliff edge' approach, regarding it as unfair and nonsensical, with a small number of calls for it to be abolished. Preferences were stated for a sliding scale or tapered approach to reducing Scottish Carer's Assistance with regards to earnings. There were a similar number of calls for taking a longer-term view of earnings in Scottish Carer's Assistance entitlement awards. A campaigning / advocacy organisation pointed out that this approach would be less burdensome for the carer to report on and less of an administrative burden for Scottish Social Security.

A need for more detail about how the 'run on' approach would work was requested by a significant minority of mainly organisation respondents, particularly regarding the duration that the 'run on' should continue for after a carer reaches the earnings limit, and its interaction with other benefits and entitlements. A local authority and a campaigning / advocacy organisation thought it would be helpful if a carer can simply resume entitlement to Scottish Carer's Assistance if their earnings fall again, subsequent to breaching the limit, rather than go through the process of a completely new application.

Amongst the comments which were more negatively disposed towards the 'run on' approach, very small numbers of individuals each saw it as being complex or difficult to administer, or viewed carers who work as being paid anyway and therefore not being a priority for receiving extra financial assistance.

Recognition or support for a wider group of unpaid carers

The consultation paper noted that there have been calls for a wider group of carers to be recognised through Scottish Carer's Assistance. This includes people who only have 'underlying entitlement' to the current benefit, i.e. those who do not receive Carer's Allowance because they get another income replacement benefit, for example, State Pension. The Scottish Government has looked at options to provide a new payment to carers with 'underlying entitlement'. A different approach could be a payment for long-term carers which would recognise the impacts on carers' finances of a long-term caring role. This approach would need to be examined to understand whether this would be feasible, its impacts and to work out more detail about who would be able to get a payment and how much it should be.

Questions 40 and 41 asked:

Question 40: Do you agree or disagree that a payment for long-term carers should be considered further?

Question 41: Please write the reason why you agree or disagree that a payment for long-term carers should be considered further, or any other information you want to share on this question.

As noted in the following table, a large majority of those answering this question (86%) agreed that a payment for long-term carers should be considered further.

Table 18: Level of agreement that a payment for long term carers should be considered further

Q40	Number (percentage *)
	Agree	Disagree	Unsure	Not answered
Organisations (n=41)	28	-	3	10
Individuals (n=151)	109	3	16	23
Total respondents (n=192)	137	3	19	33
Total respondents answering question (n=159)	137 (86%)	3 (2%)	19 (12%)

* figures may not add to 100% due to rounding

A total of 116 respondents then commented at Question 41, some of whom referred to their personal situation as a carer. A key theme, across all subgroups, and noted by a significant minority was the importance of recognising the caring role and the impacts on carers. There were comments in support of this proposal as it would help to provide financial support and stability to unpaid carers. There were also references to the contribution made by carers and the savings made for the health and social care sector. There was a general view that anyone providing care should be appropriately supported and compensated, particularly as some carers will have foregone opportunities for education, employment, career progression and building up a private pension. It was also felt that caring can have a greater impact on a person as they get older. A small minority of respondents also commented on their personal circumstances, noting they had lost income and finances in the form of salary and pension contributions, as a direct result of caring. As one campaigning / advocacy organisation commented:

"We support an approach which looks at providing longer term financial support and stability for carers. Many carers struggle to juggle their work or caring responsibilities while trying to maintain their own physical and mental health. Quite often, their own health can suffer as a result of the strain and pressure of caring. Removing financial worry for carers has the potential to make a difference to them and their family."

Entitlement to this payment was referenced by a number of respondents, with a significant minority suggesting that carers on a state pension should qualify for this payment. The key reason for this was that caring responsibilities continue after retirement and some caring roles become harder with age. Again, there were some references to the financial disadvantages experienced by carers and the savings made for the public purse due to their caring role. As well as individuals in receipt of a state pension, smaller numbers of respondents also felt that this payment should be available to:

• Those who care for the terminally ill.
• Single parents who work.
• Unpaid carers who do not qualify because of the earnings threshold.
• Anyone on a lower rate of income tax.
• All carers.
• Carers of those living with dementia.
• Two people caring for the same individual, so that both are in receipt of this payment.

While respondents generally welcomed this proposal, some noted that all carers should be able to access social security payments that give financial recognition which reflect the nature of the caring role. This was largely to counteract the poverty that many carers suffer. Suggestions included that all carers should receive the equivalent of the State Pension, that payments could correlate with the level of care provided, Universal Basic Income should be used as a basic income with top ups for any disabilities, or that carers should be paid a minimum of the living wage for the first 35 hours of care.

Benefits of this proposal were outlined by a few respondents. These were primarily that this helps to reduce the current strain felt by the care system, although there was also acknowledgement from a couple of respondents that this would remove some of the strain felt by carers.

A small minority of respondents, mostly individuals and campaigning / advocacy organisations, felt this is an area for further consideration and exploration, with references to the recent Independent Review of Adult Social Care in Scotland.

Of the small number of respondents who disagreed with this proposal, there were comments that carers will already be receiving other benefits, that there are existing schemes to provide for such carers or that those with a State Pension should not be entitled as they are already in receipt of a State Pension which is a higher amount than Carer's Allowance.

What a payment should look like and who it should be for

Questions 42 and 43 then asked:

Question 42: If a payment for long-term carers was considered, what should the payment look like and who should it be for?

Question 43: Please give us any other views you want to share about the proposals for future changes to Scottish Carer's Assistance.

A total of 107 respondents provided comments at Question 42. A wide range of suggestions were made although there was little consensus in responses, with most respondents unable to suggest a suitable amount for this payment.

A few respondents suggested there should be an additional payment each month. Alternatively, smaller numbers felt a one-off annual payment would be appropriate or suggested a weekly payment. Suggested amounts for a weekly payment ranged from £10 per week to £100 per week. A small number of respondents opted for a top up payment paid twice yearly.

Other suggestions made by small numbers of respondents were that this payment:

• Should not be means tested.
• Should be means tested.
• Should not be taxed.
• Should not impact on other benefits.
• Should be linked to the living wage rate or be based on a guaranteed universal income.
• Should be on a scale depending on the level and complexity of care provided and the skills needed to deliver this care.

In terms of who the payment should be for, a wide range of suggestions were made. The key suggestions were for all carers, those in receipt of State Pension, all carers with underlying entitlement and carers providing care for someone with a lifelong condition. Other suggestions made by small numbers of respondents included carers who:

• Care for children with lifelong disabilities.
• Care for seriously disabled individuals.
• Have cared for at least five years.
• Have cared for a long time (unspecified duration).
• Provide care and are unable to work or seek employment.
• Care for more than 35 hours a week.
• Provide care and have employment.
• Look after relatives.
• Care for the terminally ill.
• Work for more than 16 hours per week and earn above the threshold.
• Are in full time education.
• Are in a household where care is delivered by more than one person (both should be eligible).
• Are young carers.

As a third sector organisation commented:

"There needs to be recognition that long-term carers, who are providing intensive caring roles, often over many decades, need to be well supported financially and with much needed and identified care and support from health and social care. Lack of appropriate support does not assist family carers to move out of poverty but instead locks families, facing poor service provision into additional poverty."

Other views about the proposals for future changes to Scottish Carer's Assistance

A total of 70 respondents commented at Question 43, most of whom echoed points made at earlier questions; some of these welcomed the proposals for future changes, without providing much by way of additional detail. Comments included requests:

• To raise the earnings threshold, with one individual noting that work is good for the mental health of carers, albeit that some carers are unable to work due to their caring role.
• For pensioners to be awarded Scottish Carer's Assistance.
• For carers to be recognised and rewarded fairly.
• To identify all carers across Scotland to ensure all those who qualify for Scottish Carer's Assistance are aware of this.
• For two carers in the same household to qualify for Scottish Carer's Assistance where they both provide care for an individual.
• For the 35 hours caring limit to be removed, a campaigning / advocacy organisation suggested this should be lowered to 20 hours.
• For all future changes to be introduced at the launch of Scottish Carer's Assistance.
• To raise awareness of entitlement to Scottish Carer's Assistance to ensure that all who qualify for a payment are aware of this.
• For increased benefits to be offered to carers; for example, free dental care, free eye care or free TV licences.

There were a small number of comments from organisations in relation to a minimum income guarantee, with a local authority noting:

"Understanding the inter-relationships, if any exist, between SCA and any future design of a Minimum Income Guarantee will be important. There are options to incorporate contributory and non-contributory elements into these payments to ensure all those eligible, will receive a minimum level of support and those who have contributed are able to access an additional amount. This approach provides a safety net to mitigate the impacts of income shocks and provide a regular and predictable income."

Finally, a campaigning / advocacy organisation noted that social security policy for carers needs to be consistent and have coherence with other policy areas that can impact on carers, for example, the Scottish Government's broader commitments to tackle gender inequality.