Violence Against Women and Girls - Independent Strategic Review of Funding and Commissioning of Services: report

Chapter 4 – Minimum Core Services

In this chapter we set out our model for the minimum core services which, our evidence suggests, should be available to all women, children and young people who need them. The model represents a floor, not a ceiling – additional services can be provided, but there should never be fewer than those in the model.

The Model of Minimum Core Services

The first part of our remit was to develop an agreed model for services, in consultation with organisations and individuals. The evidence which fed into this included almost 100 meetings and engagement with organisations, individuals and survivors, previous research with survivors (women, children and young people), the Call for Evidence and the requirements of the Istanbul Convention and the UNCRC among other international human rights treaty requirements.

The model is intended to be a floor, not a ceiling, for services i.e. they may rise above it, but should not fall below it. Services should be appropriate for local authority areas (71% of Call for Evidence respondents agreed) and match local needs assessments which will be carried out by VAWPs (see Chapter 6 Violence Against Women's Partnerships) and across public services. It is envisaged that a small number of services may be delivered on a regional basis e.g some 'by and for' services, or services for women selling or exchanging sex, and that there will be flexibility for victims/survivors to move from one area to another to access services. There is a need for immediate, medium and longer term support, and each of these elements must be provided.

Our approach is one of targeted universalism i.e. that outcomes should be the same for all who receive services, but variations in delivery might be required to meet differing circumstances.

We envisage the implementation of the model to be based on progressive realisation of rights to services and, importantly, with no regression. In other words, we do not expect to reach the model in one step – there will be additional development work required in a number of areas and we are acutely aware of the current constraints in the public finance context. It is our strong belief, however, that we need to end the current situation within this sector where high quality services which were formerly available disappear when time limited funding comes to an end. Achieving a model based on the delivery of high quality services with sustained and appropriate levels and terms of funding should be a key deliverable for the Scottish Government and COSLA, and be integral to efforts to secure fiscally sustainable public services, through reform of service design and delivery that secures best outcomes for people across Scotland in line with the National Performance Framework and the aspirations of Scotland to be a human rights nation.

We have based our model of minimum core services on the requirements of the Istanbul Convention. Although this has been ratified by the UK Government, the services it outlines as essential are not at present universally available in any part of the UK. This is Scotland's opportunity to fully implement the Istanbul Convention, taking into account other relevant human rights instruments, in particular the UNCRC, CEDAW and ICESCR. It will also align with the Human Rights Bill currently under development by the Scottish Government which will bring existing international human rights treaties into Scots Law.

The Istanbul Convention requires states to:

……take the necessary legislative or other measures to provide or arrange for, in an adequate geographical distribution, immediate, short- and long-term specialist support services to any victim subjected to any of the acts of violence covered (1). Parties shall provide or arrange for specialist women's support services to all women victims of violence and their children. (Article 22 (2))

The preamble to the Convention notes:

'Violence against women seriously violates and impairs or nullifies the enjoyment of women of their human rights, in particular fundamental rights to life, security, freedom, dignity and physical and emotional integrity… some groups of women e.g. with disabilities are at greater risk' (para 26).

'The forms of violence covered by the scope of the Convention can have devastating consequences on victims. It is necessary to design a comprehensive framework to not only ensure their further safety, re-establish their physical and psychological health but to also enable them to re-build their lives. This framework should be grounded in a human-rights based approach.' (Explanatory note 32 re para 1 (c) of Istanbul)

Furthermore, the UN Convention on the Rights of the Child General Comment 13 asserts the right of the child to freedom from all forms of violence and states that 'no violence against children is justifiable' (3 (a)). It refers to the devastating impact of violence against children (III.15) including severe negative effects on children's survival and their "physical, mental, spiritual, moral and social development" (CRC Article 27, para 1); 'the human, social and economic costs of denying children's right to protection are enormous and unacceptable (III.16).'

It outlines a 'child's rights approach' as fundamental in responses…[that] requires …respecting and promoting the human dignity and the physical and psychological integrity of children as rights-bearing individuals rather than perceiving them primarily as "victims" (I. 3 (b)); the concept of dignity requires that every child is recognised, respected and protected as a rights holder and as a unique and valuable human being with an individual personality, distinct needs, interests and privacy (I.3(c)); the right to be heard and their views given full weight must be respected systematically in all decision-making processes and their empowerment and participation should be central to child caregiving and protection strategies and programmes (I.3 (e).') [our emphasis]

Minimum core elements

1 Legal right to services

General support services. Parties shall take the necessary legislative or other measures to ensure that victims have access to services facilitating their recovery from violence. These measures should include, when necessary, services such as legal and psychological counselling, financial assistance, housing, education, training and assistance in finding employment. (Article 20 (1))

2 Specialist Support Services

Specialist support services. Parties shall take the necessary legislative or other measures to provide or arrange for, in an adequate geographical distribution, immediate, short- and long-term specialist support services to any victim subjected to any of the acts of violence covered (1). Parties shall provide or arrange for specialist women's support services to all women victims of violence and their children. (Article 22 (2))

3 Mainstream Services

Parties shall take the necessary legislative or other measures to ensure that victims have access to health care and social services and that services are adequately resourced and professionals are trained to assist victims and refer them to the appropriate services. (Istanbul Article 20 (2)).

All who come into contact with children are aware of risk factors and indicators of all forms of violence, have received guidance on how to interpret such indicators and have the necessary knowledge, willingness and ability to take appropriate action (UNCRC Article 19, General Comment 13. 48)

4 No Recourse to Public Funds

The implementation of the provisions of this Convention by the Parties, in particular measures to protect the rights of victims, shall be secured without discrimination on any ground such as sex, gender, race, colour, language, religion, political or other opinion, national or social origin, association with a national minority, property, birth, sexual orientation, gender identity, age, state of health, disability, marital status, migrant or refugee status, or other status. [our emphasis]
(Article 4 Istanbul Convention)

While we aspire to achieving a model of services which will be widely accessible and appropriate, we understand that there is no 'one size fits all' and that some women, children and young people will prefer to make other choices than seeking help from e.g. Women's Aid or Rape Crisis. This has always been the case and it is therefore vital that mainstream and other community based services are able to provide suitable support and that their staff are trained in, and practice, trauma-informed, rights-based, risk aware, strengths-based (including children and young people), VAWCYP competent, approach.

We want to see a Scotland where the safety and needs of victims/survivors, and witnesses, including children, are central to all forms of protection provided. This includes all elements of the rights to protection and support enshrined in the Istanbul and Children's Rights Conventions, as discussed below.

1 Legal Right to Services

Parties shall take the necessary legislative or other measures to ensure that victims have access to services facilitating their recovery from violence. These measures should include, when necessary, services such as legal and psychological counselling, financial assistance, housing, education, training and assistance in finding employment. (Article 20 (1))

We asked in the Call for Evidence if there should be a legal right for women, children and young people to access services for VAWG. 84% of respondents agreed that there should be for women, and 82% for children and young people. We heard also that some people were worried that making access to services a legal right would end up restricting those services more narrowly than at present. This is obviously not an outcome we would support.

The Human Trafficking and Exploitation (Scotland) Act 2015 established a right in law to services, and therefore provides a precedent for this approach. The Forensic Medical Services (Victims of Sexual Offences) (Scotland) Act 2021 also established right to forensic medical and support services following sexual assault without having to report to police. Trafficking act also establishes right to services without having to report.

At present, services are different across Scotland and where you live or seek services affects access. There is no redress if you cannot receive a service which others in other areas can. This needs to change, and establishing a legal right to the full range of the minimum core services is the way to achieve this.

Children and young people as victims in their own right

Parties shall take the necessary legislative or other measures to ensure that in the provision of protection and support services to victims, due account is taken of the rights and needs of child witnesses of all forms of violence covered by the scope of this Convention. (Istanbul Article 26 (1))

Article 19 of the UNCRC states that parties should take all appropriate measures to protect the child from all forms of violence and protective measures should include social programmes to provide necessary support for the child and their carer/s.

CRC General Comment 13 states that strategies and systems to respond to violence must adopt a child rights approach (III.13) and 'Respect for the dignity, life, survival, well-being, health, development, participation and non-discrimination of the child as a rights-bearing person should be established and championed as the pre-eminent goal of state policies'… (V. 59)

A child-rights approach respects children as rights holders, is holistic and places emphasis on supporting the strengths and resources of the child her/himself and all social systems of which the child is a part. In VAWCYP, this means integrated services for the child/ren and the non-abusing parent/s as a primary consideration (CRC Gen Comment 13), and an understanding that children are victims in their own right in relation to VAWGCYP.

In the case of domestic abuse, for both girls and boys, being a victim in their own right can be as co-victims of domestic abuse with the non-abusing parent and siblings. This is not currently the case in Scots law in relation to the Domestic Abuse (Scotland) Act 2018, but our recommendations are based on that premise. Other forms of VAWG, such as childhood sexual abuse in particular, impact on both boys and girls (as noted in Chapter 3) and the needs and rights of boys and young men to services are unequivocally upheld in all of our recommendations.

In this report, we speak of women, children and young people throughout, where appropriate. We included in our Terms of Reference that we

regarded children and young people experiencing VAWG to be victims in their own right, not simply witnesses. We know that this will require a change in the domestic abuse legislation.

2 Specialist Support Services

Parties shall take the necessary legislative or other measures to provide or arrange for, in an adequate geographical distribution, immediate, short- and long-term specialist support services to any victim subjected to any of the acts of violence covered (1). Parties shall provide or arrange for specialist women's support services to all women victims of violence and their children. (Article 22 (2))

We have defined specialist women's and children and young people's support services as:

• Using an intersectional gendered analysis, grounded in anti-oppressive, in particular anti-racist, practices
• Having a human rights, including child rights, approach
• Consistent with Equally Safe in terms of outcomes
• Having knowledge and understanding about VAWCYP
• Having a track record of providing high quality services
• Based on an empowerment model
• Using trauma-enhanced skills

Minimum core for services: women experiencing VAWG

Our model of services is a minimum core model, i.e. all of these services should be available on the basis of need, as required by the Istanbul Convention. We are aware that there is a wide range of service providers involved in the provision of these services.

Article 23 – Parties shall take the necessary legislative or other measures to provide for the setting-up of appropriate, easily accessible shelters in sufficient numbers to provide safe accommodation for and to reach out pro-actively to victims, especially women and their children.

Article 25 – Support for victims of sexual violence Parties shall take the necessary legislative or other measures to provide for the setting up of appropriate, easily accessible rape crisis or sexual violence referral centres for victims in sufficient numbers to provide for medical and forensic examination, trauma support and counselling for victims.

Article 57 – Legal aid Parties shall provide for the right to legal assistance and to free legal aid for victims under the conditions provided by their internal law.

The minimum core services are:

Safe accommodation

Centres where services can be accessed

Support (practical/emotional/trauma/counselling/drug and alcohol support) including 1:1

Psychological therapies and interventions

Support to report, including for adult survivors of CSA

Awareness of rights, consistent with obligations to ensure knowledge of human rights and create a human rights culture

Support with medical and forensic examination

Support to leave (including financial) or to stay in their own home with the abuser removed

Support to recover including CEDAR/EYDAR (for women with children who have experienced domestic abuse)

Groupwork and peer support to be available.

Support to maintain/rebuild relationships with child/ren and social networks e.g. family, friends

Support to participate in service design, commissioning and monitoring

Support to be provided both online/using chat/telephone and face to face.

Specialist court advocacy (in any civil or criminal court processes)

Advocacy in interactions with housing/benefits

Specialist sources of support and advice including legal; financial advice; support with employment, training or education

Resources/budget to empower women to access support services that are safe, nurturing, enjoyable, creative, trauma-informed are key to involvement - - including transport, equipment, sustenance, creative resources/art collaborations, social activities and childcare and other services such as arts based therapies

Free legal aid for victims/survivors of VAWG to be a statutory right included in the legislation placing VAWG on a statutory footing

Minimum core services: children and young people experiencing VAWG

Safe accommodation

Centres where services can be accessed

1:1 Support (practical/emotional/trauma/counselling/mental health/drug and alcohol)

Age and developmentally appropriate psychosocial counselling, therapies and interventions including creative, arts and play therapy/approaches

Support to report

Awareness of rights, consistent with obligations to ensure knowledge of human rights and create a human rights culture

Support with medical and forensic examination

Support to leave, including educational support, financial support eg for clothes, toys, clubs etc. or stay in own home

Support to recover including CEDAR/EYDAR (for children experiencing domestic abuse)

Integrated support to build/maintain relationships with mother/carer and siblings, wider networks of family and friends, father if safe to do so

Groupwork and peer support to be available for all age groups

Empowering opportunities in the wider social environment and community, including play, fun, nature, leisure/sport, recreational, educational, cultural and artistic opportunities

Support to participate in service design, commissioning and monitoring

Specialist court/child protection advocacy (in any civil or criminal court processes, children's hearing or/and child protection processes)

Access to legal aid, legal advice and representation

Support to be provided both online/using chat/telephone and face to face. Face to face contact to be prioritised.

Resources to empower children to access safe, nurturing, enjoyable, creative, trauma-informed support services are key to involvement - including transport, equipment, sustenance, creative resources/art collaborations, social, purposeful and play activities.

To support the delivery of the above services for women, children and young people, and provide evidence that they are being provided, planning, needs assessments, monitoring, data and standards will be required, (see Chapter 7 Service

Standards) as will taking action to address deficits. In addition to the minimum core services, our model includes a range of further elements.

Helplines

Parties shall take the necessary legislative or other measures to set up state-wide round-the clock (24/7) telephone helplines free of charge to provide advice to callers, confidentially or with due regard for their anonymity, in relation to all forms of violence. (Article 24)

UNCRC recommends 24-hour toll-free child helplines with trained personnel (General Comment 13. Right to live free from violence. 43 (b) (i))

We do have a 24/7 helpline in Scotland, the National Domestic Abuse and Forced Marriage (NDAFM) helpline run by Scottish Women's Aid. The Rape Crisis helpline, run by Rape Crisis Scotland, is available 7/7. They also have different models of service provision so there is no consistency in approach, which represents a significant disparity in this type of support for rape victims and should be remedied. A new 24/7 rape helpline for England and Wales was announced by the UK Government in December 2022 and NHS24 provides the helpline for recent victims of sexual assault.

In relation to children and young people, the 'That's not OK' website resource was co-developed with young survivors as a result of Everyday Heroes research. ChildLine has been promoted in previous awareness campaigns to some success and the NDAFM helpline piloted national webchat for child DA victims, as recommended by young people, but this had limited use. None of these resources provide an interactive specialist resource linked to local specialist children and young people's GBV workers called for in the Review and previous

research. We heard engagement in online/phone support was difficult in lockdown for many children and young people and we have not been able to hear from a range of children e.g. with English as second language, disabled children, BSL users etc.

Accessing information

Parties shall take the necessary legislative or other measures to ensure that victims receive adequate and timely information on available support services and legal measures in a language they understand. (Istanbul Article 19)

CRC stresses the importance of increased public information programmes (IV. 44) awareness of violence against children, including its gendered nature, and the involvement of children in production and transmission of information on programmes and as reporters, analysts and commentators. (IV. 43)

Disappointingly, in spite of now 50 years of VAWG services being provided in Scotland, starting with the formation of Edinburgh and Glasgow Women's Aid in 1973, we heard often from victims/survivors that they had not known where to go for help. This was especially, but not exclusively, an experience for minority ethnic women. Children and young people said they need information about their right to protection from abuse, how to speak out and report abuse, and be reassured they will be listened to, believed and supported. More work clearly needs to be done to ensure that all who need services are aware of them, are clear what type of help is offered and how to contact them.

Adult and child victim/survivors involved in the justice system have said they and the public are not aware that some abusive behaviour is a crime, particularly in relation to the Domestic Abuse

(Scotland) Act 2018 which criminalises a course of abusive behaviour including psychological abuse but also, for example, the sexual harassment girls experience in school. Public awareness of childhood sexual abuse was noted to be low. More needs to be done to educate about abuse, the law and associated rights, including to support.

We heard of some local and national co-produced information with young people, for example the 'That's Not OK!' web resource mentioned above and an animation on GBV for children and young people in South Lanarkshire. We also heard that children would like online resources to offer support as well as information and link directly to local face to face support.

Rape and sexual assault centres

Provide for the setting up of appropriate, easily accessible rape crisis or sexual violence referral centres for victims in

sufficient numbers to provide for medical and forensic examination, trauma support and counselling for victims. (Article 25)

We heard a lot of evidence about pressures on rape crisis support, including lengthy waiting lists.

There is evidently not sufficient provision at present to either meet demand or ensure services are available for women who do not wish to access a different service offer. Further expansion of services for victims/survivors of rape and sexual assault is urgently required and should include diverse providers to ensure different needs are met.

We heard that services for child and young adult survivors of rape, sexual assault, childhood sexual abuse and exploitation needed attention. As noted above, there is a particular gap in specialist services for children (e.g. RCS support is for young women 13+) including advocacy, therapeutic recovery support and forensic services, and services for childhood sexual abuse.

Safe accommodation

Parties shall take the necessary legislative or other measures to provide for the setting-up of appropriate, easily accessible shelters in sufficient numbers to provide safe accommodation for and to reach out pro-actively to victims, especially women and their children. (Article 23)

Safe accommodation/refuges have been part of the model of services for women, children and young people experiencing domestic abuse for 50 years in Scotland. There has been little such provision for those experiencing other forms of VAWG, a notable exception being SAY Women, who provide semi-supported accommodation for young women 16–25 who have experienced sexual abuse, rape or sexual assault and are at risk of homelessness.

The preferred model of refuge provision for women, children and young people experiencing domestic abuse involved in the refuge provision research carried out by Fitzpatrick et al. in 2003 was for self-contained flats alongside rooms for peer support and in-house WA specialist

support (1:1 and group). Peer support amongst residents was very important and this included age appropriate rooms for children and young people. However, the investment of £12m in a refuge development programme only updated half the refuges and we remain in the position that the other half still include elements of sharing e.g. kitchens, bathrooms. This needs to be rectified urgently and 20 years on from this study, we still have not achieved that.

Refuge provision is not the only type of safe accommodation that addresses the needs of women, children and young people. Moving on accommodation, separate flats with support for families with additional needs/or older males all need to be part of the provision. Shared refuge does not lend itself to accommodating women, children and young people presenting with complex support needs, as we heard is increasingly the case.

Questions were raised with us about the purpose of refuge fifty years on from when it was originally established, and we are aware of research looking at different models. Other options now exist in relation to housing which were not the case 50 years ago. In the light of these questions, we did not feel that it was appropriate for us to suggest targets for refuge provision, as its purpose will obviously have an impact on demand and supply. We are aware that the Istanbul Convention suggests a target of 1 refuge space per 20,000 of the population, which may have been met in some areas, but not in all and does not necessarily fit with the preferred model.

We are also aware that there are waiting lists for refuge which are preventing some who could benefit from this service from being able to access it.

Support and safety are the most crucial elements, and we would not support any moves to reduce either of these. We feel that further scrutiny/exploration of a new model for refuge is now called for, including how safety and support can be ensured, and in the meantime, a new refuge development programme is urgently required to bring all refuge accommodation up to the preferred, i.e self-contained, model.

In addition, the role of housing more generally in providing safety for women, children and young people should be considered, see next section on Mainstream Services. It was disappointing to read the Policies not Promises report by Scottish Women's Aid and the Chartered Institute of Housing into the response by registered social landlords to domestic abuse. Providing options for families to stay in their homes rather than leave to escape abuse will not be effective unless appropriate support is also in place.

3 Mainstream Services

Parties shall take the necessary legislative or other measures to ensure that victims have access to health care and social services and that services are adequately resourced and professionals are trained to assist victims and refer them to the appropriate services. (Istanbul Article 20 (2))

All who come into contact with children are aware of risk factors and indicators of all forms of violence, have received guidance on how to interpret such indicators and have the necessary knowledge, willingness and ability to take appropriate action. (UNCRC Article 19, General Comment 13. 48)

The majority of victims and survivors of VAWCYP do not use specialist third sector organisations. Rather they interact with mainstream services seeking access to a range of support including, but not limited to, accommodation, health, criminal

justice, social care, education, financial assistance, and legal advice.

Much of the focus on addressing VAWG has understandably been on the urgent need for sufficient, sustainable funding to support the function of specialist VAWG services struggling to cope with high levels of demand that outstrip their capacity to deliver. Their symbiotic relationship with mainstream services, however, is often overlooked, which reflects not only a funding deficit but also a failure to position these services within a collaborative, multi-layered, whole systems approach to VAWG.

We have noted elsewhere the considerable costs of VAWG to the public purse that remain largely invisible in public accounting and financial allocations. This invisibility is replicated in the extent to which VAWG is absent or minimised in planning mechanisms both nationally and locally. Many respondents, for example, highlighted Community Planning as one of a number of local partnerships that do not recognise the significance of this issue in their area.

The hidden burden of VAWG on public services, inter alia, is a major impediment to realising the ambitions of Equally Safe. Upstream early engagement and intervention through universal services can prevent the entrenchment of serious harms that require complex and resource intensive intervention. The disproportionate level of presentations related to VAWG in Child Protection and Adult Support & Protection systems, Alcohol and Drug Support Services, Housing and Homelessness Support Services, Mental Health Services and Community Justice Services demands a more coherent approach to early identification and intervention that recognises the complexity of support required.

We heard a lot of evidence about inappropriate or damaging responses to presentations of VAWG and this must be addressed. We also heard examples of helpful responses, and there are clearly many professionals doing their best to offer

support. That should be the default experience and it is not currently.

Workforce training and development is essential to ensure a trauma-informed, person-centred response to VAWG. However, in isolation this is insufficient to bring about the transformation that is clearly needed. Rather, it must sit within an overall strategic and policy framework that provides a comprehensive approach to equipping the respective public services to fulfil their obligations as service providers, partners, and employers.

There are many examples of good practice across the country within and across agencies, but there was widespread recognition in the Call for Evidence that we need to focus on wider systems to embed and share good practice and to make long-term meaningful change. Two examples are offered by way of illustration:

Housing

The Domestic Abuse (Protection)(Scotland) Act 2021 has been welcomed for the way in which it has connected domestic abuse and housing policy, offering important protections to victims of such abuse. A recent report, however, highlighted a number of concerns expressed by stakeholders that may with limit its positive impact. These included the need for training police and housing staff on the implementation of the legislation, its effectiveness in relation to the private rental sector, the requirement for victims to present as homeless to secure long-term housing and the shortage of good quality, long-term, affordable housing. All of these underscore the imperative of having a coherent, resourced and collaborative approach to local implementation if the legislation is to have the desired impact.

NHS

The health service has a pivotal role in tackling VAWG. As a universal service provided from conception to grave, it is accessed by virtually all survivors of VAWG at some point. A recent report by SafeLives suggested that 80% of women

experiencing domestic abuse reported seeking help from health services, usually GPs, at least once and this may be their first or only contact with professionals. It also highlighted that 30% of domestic abuse begins or escalates during pregnancy, underlining the case for a focus on existing priority settings of midwifery and health visiting. A UK cross-government report some years ago suggested that 50-60% of inpatients and 40-60% of outpatients in mental health services have been victims of sexual violence and/or childhood sexual abuse.

The creation of a dedicated programme of work on VAWG within NHS Scotland in 2009 introduced routine enquiry of abuse in a number of priority services to support early identification and response to domestic and sexual abuse. It also established strategic and operational leads with a responsibility for gender-based violence in each NHS Board. This infrastructure has endured, but there is disparity across the country in terms of resource allocation. The lack of reaffirmation of the programme has also led to attrition in rates of routine enquiry within some areas as well as difficulties in accessing data on VAWG related presentations.

Developing a policy and practice response that will build on this previous commitment, ensuring that there is national leadership and governance, and strengthening the capacity of NHS staff and services to respond to VAWG would be both an efficient and effective approach to support the NHS to deliver on Equally Safe. Maximising the public health expertise in relation to prevention, data collection and analysis, and evidence-based interventions requires additional resources but would be cost effective and fruitful for individual agencies and partnerships.

A whole-system, gendered response to VAWG is a prerequisite to achieving the transformational shift required. At a local level, there needs to be investment to support the shift from crisis management and reactive service provision to

prevention and early intervention. Universal, mainstream services are at the heart of this transformation.

4 No Recourse to Public Funds (NRPF)

Article 4 Istanbul Convention: The implementation of the provisions of this Convention by the Parties, in particular measures to protect the rights of victims, shall be secured without discrimination on any ground such as sex, gender, race, colour, language, religion, political or other opinion, national or social origin, association with a national minority, property, birth, sexual orientation, gender identity, age, state of health, disability, marital status, migrant or refugee status, or other status. [our emphasis]

In her report Safety before Status: the Solutions, published in December 2022, the Domestic Abuse Commissioner for England and Wales sets out options for the Home Office to end the current practice of denying support to women with No Recourse to Public Funds. We support her call to the UK Government to make this change, which, as she demonstrates, has implications for individual wellbeing in ratio to the costs to public finance.

Given that this might take some time, and is not within the competence of the Scottish Government, we are suggesting an interim approach for Scotland. Part of our task is to learn lessons from Covid, and one of the most compelling is that a way was found, during lockdown, to circumvent the NRPF regulations and provide services to those in need, regardless of their immigration status. Although the Destitute Domestic Violence Concession for domestic abuse survivors has been in place for many years, this is restricted to women who arrive in the UK on spousal visas.

During lockdown, NRPF was circumvented by using public health legislation, which is not likely to be appropriate in the longer term. As an alternative, given that women with children should at present receive support from local authorities under their duties to children and young people (although we have heard that this has needed to be argued by support organisations), we suggest that single women who have experienced VAWG should be automatically classed as 'vulnerable', which enables them to receive support.

In its response to the Work and Pensions Select Committee's report and recommendations on Children in Poverty: No Recourse to Public Funds, the UK Government asserted that

"The Government is committed to supporting all victims of domestic abuse. Anyone who has suffered domestic abuse must be treated as a victim first and foremost, regardless of immigration status."

Furthermore it committed "£1.4 million in 2022–23 to continue to fund support for migrant victims of domestic abuse, while we take on board vital lessons learned from the pilot to inform our future policy decisions". We are interested to know what portion of that additional funding has come to Scotland under fiscal arrangements and how it has been allocated within the Scottish Budget.