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.
Section 2. Extra Money for Carers
Introduction
Section 2 of the consultation set out proposals for extra support for carers in Scotland – the future of Carer’s Allowance Supplement, an additional amount which has been paid to carers getting Carer’s Allowance in Scotland since 2018, worth over £491 a year in 2022, and Carer's Additional Person Payment – a proposed new extra payment for carers with multiple caring roles.
Carer’s Allowance Supplement
When Carer Support Payment begins, Carer’s Allowance Supplement will continue to be paid in the same way as it is now, to protect the safe and secure transfer of benefits for carers in Scotland who are already getting Carer’s Allowance. Carer’s Allowance Supplement is currently paid twice a year automatically, using information on people living in Scotland and getting Carer’s Allowance on a specific qualifying date, with no need to apply.
The consultation proposed that Carer’s Allowance Supplement could be paid alongside carers’ regular payments of Carer Support Payment in future. This could mean carers would receive higher regular payments and would reduce the risk of over or underpayments of support.
Respondents’ feedback
A majority of respondents (62%) agreed with the proposal to pay Carer’s Allowance Supplement alongside regular payments of Carer Support Payment in future. Reasons given were that this would be better for budgeting and would provide a more stable income.
However, there were also those in favour of keeping Carer’s Allowance Supplement as a lump sum payment. Reasons given for this were that it would be a more noticeable amount when paid twice yearly, could help with unexpected bills, and can be helpful at certain times of the year such as Christmas when outgoings may be higher than usual. It was also noted by some that this could make the system simpler.
A number of people were unsure, and some, mostly organisations, suggested that carers should be given the choice of how to receive the payment, with any approach to future payments needing to be co-designed with carers.
A number of respondents also made points about eligibility for Carer’s Allowance Supplement and expressed a view that carers with ‘underlying entitlement’, or all carers should receive this payment. Some people felt the payment should be a higher amount.
Scottish Government response
As a majority (62%) agreed with the approach set out in the consultation, to pay Carer Allowance Supplement alongside regular payments of Carer Support Payment, we will proceed with this.
As retaining a lump sum approach would require the use of qualifying dates which could disadvantage some carers and increase the amount of over and underpayments of support, we consider that providing regular payments would be fairer for carers, ensuring all carers receive the right amount of support. As noted by respondents this would be of particular importance to those on lower incomes as it would a provide a higher regular and more stable income which would be better for budgeting.
We also appreciate the points raised around allowing a choice of payment options for carers. While we do want to ensure there is flexibility for carers in Carer Support Payment, running parallel systems for Carer’s Allowance Supplement so that some carers would receive lump sums and others could receive regular payments would add significant complexity, cost, and risk to the system.
In relation to the points on co-design, we are working with carers and support organisations to ensure our policy, systems and services are shaped by the people who will use the benefit, through regular user research and user testing. As noted in the consultation, we recognise that we will need to provide clear communications to carers around any changes to Carer’s Allowance Supplement and to support understanding of how it will be treated differently in reserved benefits, even where it is paid alongside regular payments of Carer Support Payment. It will be particularly important to ensure these communications are developed with carers and support organisations so that they work for the people who will use them.
Timings for the changes to Carer’s Allowance Supplement are being considered as part of wider work to consider future changes to Carer Support Payment and the delivery of Carer's Additional Person Payment. We will uprate all Scottish benefits, including Carer’s Allowance Supplement and Young Carer Grant, in line with inflation, by 10.1% in April 2023.
Carer's Additional Person Payment
There is no additional support available through the current system of Carer’s Allowance for carers with multiple caring roles. The consultation set out proposals for Carer's Additional Person Payment – a new payment to provide extra support for carers who are getting Carer Support Payment and caring for more than one person who is getting a disability benefit.
We have been working with the Department for Work and Pensions to explore in detail a number of options to introduce Carer's Additional Person Payment as early as possible ahead of completing the transfer of cases from the Department of Work and Pensions to Social Security Scotland. This would allow people already getting Carer’s Allowance to benefit from the extra support at same time as new applicants.
However, the detailed work carried out on these options identified that the complexity of the current Carer’s Allowance benefit, and the age of the Department of Work and Pensions systems, would mean that making a change of this size before case transfer was complete would pose too great a risk to the safe and secure transfer of carers’ benefits and to wider delivery of Carer Support Payment.
We will therefore begin the new payment after all eligible carers have had their benefits safely transferred from Carer’s Allowance to Carer Support Payment. We will continue to work with the Department for Work and Pensions to deliver Carer’s Additional Person Payment as soon as possible once case transfer is complete.
Carer's Additional Person Payment – eligibility
In the consultation, we set out that to qualify for Carer’s Additional Person Payment, carers must be eligible for Carer Support Payment and receiving payments of the benefit.
The consultation also proposed that carers would need to be caring for at least two people who are in receipt of a Carer Support Payment qualifying benefit[18]. Carers would need to be providing at least 20 hours of care per week for each additional person, as well as at least 35 hours of care a week for the person for whom they are receiving Carer Support Payment. There could only be one award of Carer’s Additional Person Payment per cared for person, but carers would be able to receive more than one award of Carer's Additional Person Payment if they are caring for more than two people.
Respondents’ feedback
The majority (72%) of respondents agreed with the proposed eligibility criteria for Carer’s Additional Person Payment, with some noting that this approach recognises the financial burden faced by carers of having to care for more than one person.
However there were mixed responses on this and some respondents felt that the rate for Carer’s Additional Person Payment should be more than £10 per week, with some respondents noting it felt insufficient in relation to the caring hours requirement. Some respondents felt that either this rate should be increased or the minimum of 20 hours of care required should be reduced.
Scottish Government response
We acknowledge the support from the majority of respondents. We appreciate the points raised in relation to the level of the payment and the number of caring hours. We would note that Carer's Additional Person Payment is not intended as a payment for care – it is an extra amount of support for those with multiple caring roles in recognition of the additional impact this can have on their wellbeing. This is considered further in the next section.
We discussed the caring hours requirement with the Carer Benefits Advisory Group ahead of the consultation and this was lowered from 35 hours to 20 hours as it was considered this would support more carers while still representing a significant caring role for any additional people. This was in light of evidence showing that 20 hours is a key point at which the impact of caring starts to be felt in terms of a carer’s health and employment. The data on the number of Carer’s Allowance recipients currently caring for more than one person is limited. Reducing the caring hours requirement to below 20 hours would expand eligibility further but may not target support at those with the most intensive caring roles. We will continue to consider the consultation feedback in our work to develop detailed policy for Carer's Additional Person Payment.
We are also continuing to consider the potential interactions between Carer's Additional Person Payment and the proposed change (in section 3 below) to allow carers to add together hours of care for two people in receipt of a qualifying benefit, in our work to finalise policy on the eligibility criteria. We recognise that these proposals may add complexity to the application and administrative process and will continue to consider this throughout policy development.
Carer's Additional Person Payment – frequency of payments
The consultation proposed that the payment would be equivalent to £10 per week for each additional person cared for. This payment would then be up-rated each year. It was also proposed that the extra payment would be paid at the same time as Carer Support Payment and that this would be paid alongside a carer’s regular payments of Carer Support Payment. The consultation noted that most carers received payments of Carer’s Allowance either weekly or every four weeks and asked for views on the proposed payment frequency.
Respondents’ feedback
The majority (73%) of respondents agreed with the proposed payment frequency. Some organisations also noted that the proposed frequency would be good for budgeting purposes as respondents would receive smaller, more regular payments, when compared with a larger lump sum payment.
Respondents also noted that regular payments, rather than lump sum payments, could help to avoid confusion, reduce the administrative burden on Social Security Scotland and avoid the risk of under or overpayments associated with lump sums.
Some organisations called for a need to offer choice to carers as to when to receive these payments, to allow them to receive payments in the way that best suits their needs.
As with the previous question, some respondents noted that the rate should be more than £10, given that all cared for persons would be receiving the same level of care.
Scottish Government response
The responses were mixed on payment frequency, with some preferring more frequent payments and others preferring a larger lump sum payment, and some calling for a choice of payment frequency.
As a majority of respondents were in favour of payment alongside regular payments of Carer Support Payment, we propose to proceed with this plan. As noted above, we plan to pay Carer Support Payment every four weeks for those making new applications. Paying Carer's Additional Person Payment alongside this will allow carers to receive a higher income more regularly. However, we recognise the calls for choice in payment frequencies for carers, and following Carer Support Payment and subsequent Carer's Additional Person Payment launch we will continue to consider feedback from carers and others, and consider whether changes to the offer are needed.
Carer's Additional Person Payment – targeting
The consultation explained the proposal to target Carer's Additional Person Payment to people getting payments of Carer Support Payment and not those with ‘underlying entitlement,’ or those who receive only the Universal Credit Carer Element. This would be in line with how Carer’s Allowance Supplement works now.
Respondents’ feedback
The majority of respondents (63%) agreed with this proposal, with comments noting that this would be fair, sensible, logical and reasonable. Some organisations called for payments to be made to those with ‘underlying entitlement’ and some requested that it should be extended to those in receipt of State Pension in particular.
Some organisations also noted the need for collaboration between Social Security Scotland and the Department for Work and Pensions in order to identify carers on Universal Credit who may be entitled to additional support. Furthermore, some organisations suggested that carers should be able to seek advice from a Social Security Scotland adviser on whether they would be entitled to additional support.
Scottish Government response
Based on the support from the majority of respondents, we propose to proceed with targeting the extra payment at those carers in receipt of Carer Support Payment and not those with ‘underlying entitlement’ or those in receipt of the Universal Credit Carer Element only. Whilst we do appreciate comments from organisations regarding those with ‘underlying entitlement,’ the reason this additional support would be targeted at those in receipt of Carer Support Payment is that these carers are likely to be those on the lowest incomes. Carers with ‘underlying entitlement’ will be in receipt of other support which is paid at a higher rate, such as State Pension. This approach would avoid confusion as it aligns with how Carer’s Allowance Supplement works today which also targets those in receipt of Carer’s Allowance (and in future Carer Support Payment).
In discussions with stakeholders on this point, it was considered that the wider issue of support for carers on State Pension may be better considered separately from Carer's Additional Person Payment, as not all carers will have multiple caring roles. The consultation sought views on whether a recognition payment for long term carers could be considered to provide support to these carers. More information on the ‘Carer Recognition Payment’ responses is in section 3 below.
On identifying and advising those claimants who may be entitled to further support, we will provide clear communications for carers who are getting Universal Credit, or applying for it, to help them find out if they would be better off if they applied for Carer Support Payment as well. As part of our development of providing information and notifications, we are working with carers and support organisations to ensure information and signposting is clear and shaped by the people who will use the benefit, through regular user research and user testing. Social Security Scotland advisers would also be able to signpost carers to additional support they may be entitled to, but it is also important to note that the circumstances of carers and the people they care for will vary.
Contact
Email: CarerSupportPayment@gov.scot
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