The Welfare Foods (Best Start Foods) (Scotland) Amendment Regulations 2023: business and regulatory impact assessment

Regulatory and EU Alignment Impacts

Intra-UK Trade

There is not likely to be any impact on intra-UK trade as a result of these changes.

International Trade

The changes we are making to BSF will have no impact on international trade and investment.

EU Alignment

The policy changes we are making are not likely to impact on the Scottish Government’s policy to maintain alignment with the EU.

Scottish Firms Impact Test

There has been extensive engagement with a wide range of stakeholders throughout development of these policy proposals to understand the impact of the policy on the third sector and the groups they represent.

We held a meeting with our Five Family Payments Reference Group, which is made up of a number of key stakeholders with an interest in the policy area, in March 2023. We provided them with an overview of our proposed changes and following this we met separately with some of the individual members.

The overall feedback we received was positive. Removal of the income thresholds was welcomed by stakeholders and considered to be particularly helpful for people who do seasonal work, have variable incomes or are on flexible contracts. It was noted that the existing threshold for UC can prevent parents accepting work that is paid at the real Living Wage. A risk was also highlighted that people who currently lose entitlement due to breaching the income thresholds (and who do not fall below the threshold within 12 weeks of losing their entitlement) might not reclaim when their income reduces again, resulting in individuals not receiving the support they are entitled to. Providing a further eight weeks entitlement to BSF when entitlement to Child Tax Credit, Working Tax Credit, Income Support, Income-based Jobseekers Allowance, Income-related Employment and Support Allowance, Pension Credit or Housing Benefit ends was also viewed positively and considered to be especially helpful when issues arise with qualifying benefits which can take some time to resolve. Changes to improve access to BSF for young parents were also welcomed and it was anticipated that they would help improve uptake. Making WTC a qualifying benefit in its own right was viewed as particularly positive for some pregnant persons and also for some carers who are not responsible for the child for CTC purposes, e.g. some kinship carers. In general, further aligning eligibility for BSF with BSG and SCP was also received positively as it was acknowledged that the differences in eligibility can be confusing for some parents.

We have also engaged with the Scottish Women’s Convention and Nourish Scotland. Overall, the feedback received was that the changes being made are very positive and progressive. Changes which will make it easier for eligible families to access BSF were welcomed. Providing a further eight weeks entitlement to BSF when entitlement to Child Tax Credit, Working Tax Credit, Income Support, Income-based Jobseekers Allowance, Income-related Employment and Support Allowance, Pension Credit or Housing Benefit ends was specifically highlighted as a good example of how to treat individuals well.

It is expected that increasing eligibility for BSF could cause additional requests for information and support from existing advice services. As highlighted within the second Benefit Take-up Strategy,^[23] the Scottish Government has committed to provide funding over this parliamentary term to increase access to advice services within accessible settings, for example schools, to maximise incomes, tackle the poverty penalty and improve wellbeing.

In 2023-24, the Scottish Government will allocate £11.7 million to support the provision of free income maximisation, welfare and debt advice.

As part of this, the Scottish Government has committed £3.52 million over three years, from 2021, placing welfare rights advisors in up to 180 GP practices across Scotland’s most deprived areas. Evidence has shown that money and welfare advisors in health centres often reach people who do not engage with traditional advice services.

Local delivery is the face to face channel of Social Security Scotland, providing pre-claim support to clients accessing the Scottish benefits system. The Local Delivery service is made up of specially trained Client Support Advisers who are based within every local authority area in Scotland including our island communities. The Local Delivery Relationship Leads have built close relationships with Local Authorities, Health & Social Care and Third Sector agencies creating opportunities to co-locate Social Security Scotland staff and deliver a service that is tailored to meet the differing needs of each individual area. Clients can book an appointment to meet with an adviser at a venue within their local community or at their home and are also able to request video call or telephone appointments.