The Social Security (Miscellaneous Amendment and Transitional Provision) (Scotland) Regulations 2022: child rights and wellbeing impact assessment

6. How have you consulted with relevant stakeholders, including involving children and young people in the development of the policy/measure?

There has been policy engagement with stakeholders throughout the development of the FFP and since launch. This has included workshops with anti-poverty organisations, think tanks, local authorities and academia to develop the policy and delivery model for them. We have held one to one meetings and attended a number of member events organised by the Scottish Campaign for Welfare Reform, the Social Security Consortium in Scotland and the Poverty Alliance, amongst others. These events have been designed to seek views on the policy for the FFP, identify any barriers towards claiming, and consider how we can best maximise uptake of the benefit.

We also hosted a series of events and meetings to consider the impact of the FFP on those with protected characteristics, including on young people. We engaged with Fife Gingerbread; Young Scot; Inclusion Scotland; CEMVO Scotland; Engender; Scottish Women's Aid; Families Outside; Shakti; and religious groups.

The Cabinet Secretary for Social Security and Older People hosted a stakeholder roundtable in January 2020 in relation to SCP, which was an open discussion with key stakeholders allowing them to ask questions about the policy and delivery of the benefit. The Cabinet Secretary for Social Justice, Housing and Local Government held an additional roundtable with stakeholders in August 2021.

We have also held a number of meetings with our Five Family Payments Reference Group, which is made up of a number of key stakeholders with an interest in the policy area, including Child Poverty Action Group, Citizens Advice Scotland, Engender and a number of other groups.

At our meeting in January 2022, we provided the Reference Group with an overview of our proposed changes. The overall feedback we received was positive. It was felt that introducing auto-award for elements of BSG would make it easier for people to receive what they are entitled to. There was a suggestion that BSG would need to be auto-awarded to the person who would normally have applied for it and that this might not be the person receiving SCP for the child. However, we are only able to auto-award payments on the basis of an individual receiving SCP. As we set out above, SCP is paid to the main carer of the child. However, where someone contacts the agency to ask not to be auto-awarded Early Learning or School Age Payment they can be removed from the process, allowing another eligible person to apply within the application window.

In relation to providing new exceptions to the general rule that an individual is only entitled to the higher Pregnancy and Baby Payment when they are applying in respect of their first child, it was highlighted that it will be important to work with relevant third sector organisations to raise awareness among refugees who may be eligible. We intend to work with a range of stakeholders to promote awareness of all of the changes we are making. It was also suggested that those who have been forced to leave their home due to domestic abuse should be included and we have now expanded on our original proposals to include this group.

In relation to SCP, the proposed improvements to the regulations were viewed overwhelmingly positively and thought to better match policy intent as part of the extension to children aged between 6 and 15. Generally, stakeholders were positive about efforts to drive take-up of SCP. It was suggested that a significant effort must be taken to ensure take-up amongst those families who had received SCP for a child who ages out before the extension of the payment to older children. This will be addressed through a comprehensive communications and engagement plan featuring targeted communications and local delivery.

We consulted with island stakeholders as part of the Islands Community Impact Assessment process and some of the feedback raised by islands stakeholders was relevant to this impact assessment. One stakeholder told us that removal of the condition that the child is not looked after by the local authority in residential care will support families dealing with children in care situations, which can often be fluid depending on the circumstances of the case. It was felt that this change could be seen to be in line with the objectives of The Promise^[19] and supportive of children both in care and returning home.

The proposal to provide new exceptions to the general rule that an individual is only entitled to the higher Pregnancy and Baby Payment when they are applying in respect of their first child was also welcomed. The exception being made for parents or carers of a child who came into their care after 12 months old was thought to be important to support and encourage kinship care arrangements and help to keep more children within their extended family.

Finally, it was highlighted that for auto-award it would be important to ensure that where families are in crisis or transition (through domestic violence, children coming into care or moving in and out of kinship care etc.) that the benefits are paid to the appropriate people.

The SCoSS scrutiny report on the original regulations for SCP^[20] recognised the challenges of engaging directly with children aged under 6, however, we engaged with representatives of children and young people, such as Young Scot and Who Cares Scotland, and met with young parents via Fife Gingerbread to learn directly from their experiences.

These events were designed to seek views on the policy for SCP, identify any barriers towards claiming and consider how we can best maximise uptake of the benefit. Those we engaged with were highly supportive of SCP policy telling us that it would make a tangible difference to the lives of children and young people. The most important thing is that young people are made aware of their eligibility.

We recognise the value of consulting children and young people directly, as well as through representative organisations and will continue to explore further engagement once the payment has been rolled out to older children.