Social security - Scottish Carer's Assistance consultation: Scottish Government response
Our response to the consultation analysis report about the Scottish Carer's Assistance consultation undertaken between 28 February 2022 and 25 May 2022.
Background to the consultation process
A range of proposals for changes to Carer’s Allowance were developed over a number of years with stakeholders, including unpaid carers and organisations that work with and represent them. As part of this process we worked with stakeholders to agree the aims for our replacement for Carer’s Allowance.
In March 2020, we published a discussion paper on Scottish Carer’s Assistance[6], setting out draft aims for the new support, taking into account the purpose of the benefit – to provide replacement income for carers with the most intensive caring roles.
After we published the draft aims, we held events with carer support organisations and others and carried out a number of interviews with members of our Experience Panels to take feedback. We also worked with the Disability and Carer Benefits Expert Advisory Group[7], which provides independent expert advice on disability and carer benefits, and the Carer Benefits Advisory Group[8], which includes representatives from National Carer Organisations[9], carer services, health and social care, local authorities and welfare advice organisations. We updated the aims based on all of this feedback.
The aims of Carer Support Payment are designed to guide decisions about how the benefit will work and to help us assess how well changes made, will make a difference for carers.
Aim 1. Carer Support Payment provides income for unpaid carers in recognition of their vital role and it’s impacts on their lives and is delivered in a way that takes into account different caring needs and the impacts on carers.
Aim 2. Carer Support Payment provides stability and support for carers to have access to opportunities outside of caring, where possible and should they wish to do so.
Aim 3. Carer Support Payment is designed to ensure that carers have a positive experience of the social security system, and to maximise carers’ take-up of all support available to them.
The 15 options for change developed with stakeholders were then assessed and prioritised using a Multi Criteria Analysis process[10], which looked at how the different changes would best help to deliver the aims. The process looked at various options and were ranked in terms of how well they would meet a set of 18 criteria. This included equality and poverty considerations, protecting existing support, keeping application processes simple, removing barriers to work, cost, and promoting take-up. The conclusions of this process informed the proposals taken into our consultation.
About the consultation process
The consultation opened on 28th February 2022 and asked about how our replacement benefit for Carer’s Allowance could work better for carers, from launch, and in future. It also included proposals relating to extra payments for carers – the future of Carer’s Allowance Supplement and a new benefit known as Carer's Additional Person Payment. It closed on 23rd May 2022 with around 200 responses.
During this time officials attended Carers Scotland’s Annual Carers Summit and took part in nine engagement events to hear from a wide and diverse range of carers, including seldom heard groups such as those with sensory loss and learning disabilities, rural and island communities, ethnic minority communities and women’s equality and advocacy representatives.
From March until April 2022, 242 Experience Panel members, took part in surveys on the proposals. Survey respondents were asked to take part in follow-up interviews and a total of 15 interviews were conducted between June and July 2022 on detailed policy and how the proposals might work, with the aim of identifying any gaps or unintended consequences. The Experience Panel report[11] was published in November 2022. The findings are being considered alongside the consultation responses to help inform decisions on the policy and delivery of Carer Support Payment.
About this paper
The next sections of this paper provide a summary of the key findings from the analysis of the consultation and a summary of the Scottish Government’s response to this, before setting out the next steps. Further detail on the Scottish Government’s response can be found in the following sections of this paper.
- Section 1: Carer Support Payment
- Section 2: Extra money for carers
- Section 3: Changes to Carer Support Payment
- Section 4: Impact assessments, monitoring and continuous improvement
Key findings from the analysis
The consultation built on all of our work and research to date, to consider how our replacement benefit could improve Carer’s Allowance. It was designed to gather views on policy proposals and identify any gaps or arising issues. An independent analysis of the consultation responses was carried out by Why Research[12] and was published in November 2022.
Overall, the proposals set out in the consultation paper were welcomed, with many noting the need for changes from the current Carer’s Allowance system. Some people felt the proposals did not go far enough and that changes could be made quicker, with proposals for future changes to be made from launch instead. There were some references to the amount of money saved by unpaid carers for the public purse, comments that payments for carers were too low, calls for all carers to receive the benefit and for additional assistance to be available to carers, such as help with utility bills and travel costs. Some respondents called for carers to be paid the minimum or living wage for the hours of caring they provide.
Other themes in the response were the need for clear information about benefits in a variety of different formats and for carers to have access to a range of ways to contact Social Security Scotland, as well as fast, straightforward application processes, with calls for a co-design approach in the development of the new benefit. A number of respondents, particularly organisations, asked for support to be available to carers through improved signposting for benefit advice, income maximisation, and advocacy services. Respondents also felt support should be provided at key points in a caring role, particularly when a cared for person dies or when a caring role ends.
There were requests for flexible payment options (weekly, monthly or bi-annually) to suit individual needs. A high number of respondents said they would like carers to be able to work for a greater number of hours while still receiving support and welcomed proposed increases in the earnings threshold[13], noting the positive impacts on carers’ finances and wellbeing of being able to take on paid work.
There were comments that the new benefit should recognise different caring situations better, for example, where more than one person is sharing care for someone with more complex needs or for those with ‘underlying entitlement’[14], particularly for those receiving State Pension.
Scottish Government response
We welcome the high number of responses and are grateful to the carers and organisations who have supported the development of the proposals and responded to the consultation. The support for the proposals reflects the valuable advice which has been provided by carers, our Carer Benefits Advisory Group, Disability and Carer Benefits Advisory Group, Experience Panel members, and others. The detailed design and delivery of Carer Support Payment will continue to be based on user research and ongoing engagement with unpaid carers and organisations that work with and represent them, to ensure the benefit and our services work well for all those who will use them.
When we first launch Carer Support Payment the rules will broadly mirror Carer’s Allowance. This is because we want to avoid a ‘two tier’ system which would treat carers in Scotland who are already getting Carer’s Allowance, differently from those newly applying. Our first priority has to be the safe and secure transfer of carers’ benefits from Carer’s Allowance provided by the Department of Work and Pensions to Carer Support Payment provided by Social Security Scotland. We also need to make sure Carer Support Payment works with UK Government reserved benefits and systems. We can’t make any changes from launch that would put carers’ existing support at risk.
We recognise that carers and others are keen to see changes as soon as possible. We have been ambitious with the improvements proposed as these are the changes carers have told us they wish to see and we want to make improvements as soon as we can. From launch, we will aim to align the ‘past presence test’ for Carer Support Payment with our disability benefits, meaning those moving to Scotland from outside of the Common Travel Area can access support more quickly. We also intend to introduce changes to extend entitlement to many carers in full-time studies reducing barriers to education and supporting student carers. This is an important first step in our journey to ensure our benefit better meets the needs of carers.
We also intend to provide a better service of support to carers at launch, making sure that they are signposted to wider services. We are working with Social Security Scotland’s Local Delivery Service to ensure carers have information and advice on all of the support available to them. Over the longer term, we also plan to link carers to other services at key moments of transition, such as the start or end of a caring role or when a cared for person dies. We also plan to support carers to access opportunities outside of caring, should they wish to, by linking to information and advice on education, training, work, and other opportunities.
We aim to introduce new extra support for those caring for more than one person – known as Carer’s Additional Person Payment – and increase the ‘run on’ of support after a cared for person dies from 8 to 12 weeks. We will deliver this as soon as practicable after we have safely and securely transferred the awards of all those in Scotland currently receiving Carer’s Allowance to Carer Support Payment.
After launch, we will continue to develop proposals to deliver the other improvements in the consultation, monitor how we deliver the benefit to ensure it works for carers and to consider how future changes fit with wider improvements we are making for unpaid carers and the people they care for. This will include the commitment to deliver a National Care Service and the potential for a Minimum Income Guarantee for all. We hope this demonstrates our ambition and commitment to improving how we recognise and support carers in Scotland.
Next steps
We will begin to roll out Carer Support Payment, our replacement for Carer’s Allowance by the end of 2023, with full national introduction in spring 2024.
We are currently working on the system build and final policy details. We are also working with Social Security Scotland to ensure we have all of the resources needed to deliver the new benefit and in-line with our timetable for delivery. We will continue to engage on Carer Support Payment with key stakeholders and with others who will access this support, as it is important that we test everything, so that we get it right.
The Scottish Commission on Social Security (SCoSS) will provide independent scrutiny of the regulations needed for Carer Support Payment before they are laid in the Scottish Parliament later this year.
We are also continuing to work closely with the Department for Work and Pensions ahead of the transfer of carers’ benefits to Social Security Scotland. This is a very complex process given the interactions between carer benefits, reserved benefits and tax systems and the age and structure of the Department of Work and Pension’s Carer’s Allowance systems.
We will continue to work to deliver our commitments to a Carer’s Additional Person Payment and extended support for carers after the loss of a cared for person, as soon as possible after case transfer completes. The consultation response will also continue to inform our ongoing consideration of future improvements which could be made to support for carers as set out in the consultation. We will also continue to engage and importantly, listen to those with lived experience of being a carer, to inform the design and delivery of support for unpaid carers in Scotland.
Contact
Email: CarerSupportPayment@gov.scot
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