The Welfare Foods (Best Start Foods) (Scotland) Amendment Regulations 2023: islands community impact assessment

Step Four - Assessment

Does your assessment identify any unique impacts on island communities?

Demographic

• The policy is likely to have a positive impact as widening eligibility and making it easier to access BSF will benefit low income families across the islands by increasing their income. Therefore, it may make it easier to sustain residency on an island where the cost of living can be higher.
• One island stakeholder told us that BSF helps to support increased local spend, which in turn helps to create and increase employment opportunities, and to participate in community living and community development. Together, these contribute, albeit in a small way, to help address depopulation.

Economic

• Island stakeholders have told us that they felt that these social security payments have wider benefits of boosting local economies as result of spend in local shops and businesses, supporting responsible social behaviours and positively impacting health outcomes.
• The policy is not reliant on high-capacity broadband or access to public transport and is therefore not likely to lead to unfair access. Social Security Scotland take a multi-channel approach and therefore applications can be made online, in writing, by telephone or in person. Support during the application process can be provided via webchat, by telephone or in person.

Gaelic

• Social Security Scotland currently creates all its promotional materials in seven alternative community languages including Gaelic.

Social

• The policy is likely to have a positive impact by increasing incomes for more low income families. The payments are likely to be helpful in meeting the increased cost of living in island communities.

Does your assessment identify any potential barriers or wider impacts?

Accessibility, stigma and the higher cost of living in island communities have all been identified as potential barriers by island stakeholders

Accessibility

• Limited public transport, the extended time required to travel and increased costs to attend appointments were highlighted by island stakeholders as was a lack of digital technology, connectivity and skills. It was noted that some island groups have better transport links than others.
• The need for equality of access to face to face support was said to be very important for income maximisation support services.
• While Social Security Scotland was said to be working well with local stakeholders to raise awareness, one stakeholder told us that the face to face service available from Social Security Scotland was currently limited and not yet able to respond to the full needs of island residents. They highlighted that existing local advice provision via both the local authority and the third sector was important in ensuring access to entitlement and that there was scope for them to deliver support on behalf of Social Security Scotland.
• Stakeholders also noted that Island communities do not generally have leading supermarket chains within their locale and are not therefore able to take advantage of competitive pricing or doorstep deliveries from local stores. Island communities are instead dependent on small independent retailers where the costs of individual food items typically cost more and the quality and range of affordable foods are limited. For those who are able to travel to their nearest supermarket, the savings made on more competitively priced foods can be negated by travel costs. Travel time is another factor that often prohibits access to supermarket pricing, range and quality.
• One stakeholder also highlighted the need to accelerate improved alignment of eligibility criteria and remove the need for application-based approaches. Data sharing, passporting and automatic awards were viewed as steps which would ensure that those with an entitlement to BSF are able to enjoy and take advantage of the intended health benefits during pregnancy and for child development and wellbeing. Furthermore, automatic awards were seen as one way in which to reduce the administrative burden and therefore the administrative costs of delivering BSF.

Stigma

• It was noted that stigma is a highly prevalent factor when living on a low income and particularly stigma related to the social security system.
• Levels of stigma were seen to vary between islands and island groups.
• We heard that the proportion of incomers in island communities and the size of those communities could impact the level of stigma, and also that stigma was more prevalent in smaller communities, where people living with financial hardship are living close to those with relative wealth.
• One island stakeholder commented that as a general principle they favour cash-first approaches, in preference to vouchers or cards, for anyone experiencing financial hardship.

Other

• Stakeholders cautioned that by allowing the individual who a pregnant person is dependent upon to be eligible to receive BSF, the independence of the young person could be adversely affected and it could make them vulnerable to abuse from coercive grandparents.

Cost of Living

• It was noted that there is generally a higher cost of living in the islands
• The cost of living was said to be particularly higher during winter and the cost-of-living crisis was likely to be more challenging for more remote communities
• As a result of the higher cost of living in island communities, it was felt that the value of BSF in real terms, would be less in island communities though it would differ between places due to geography or transport links.
• Stakeholders explained that there is a limited supply and limited range of foods available locally for island communities and that the current proposals do not cater for the increased costs of island living. Island families are unable to take advantage of competitive pricing available in leading supermarkets operating mainly in urban localities. While BSF is a prepaid card which can be used to make online purchases of food, there are inherent delays with deliveries from distant suppliers to island communities and online purchases to these locations incur high delivery charges, thus depleting the real terms financial value of BSF.
• One stakeholder fed back that if the amount of BSF is the same across the whole of Scotland, then the real terms financial value of BSF to those living in an island community is notably less than it is for urban dwellers. Consequently, the policy intent of BSF is diluted when applying it to island residents. They suggested that to overcome this we could implement automatic additional payments (an island top-up) to those residing in island communities.

Are there mitigations already in place for these impacts raised?

Accessibility

• Island stakeholders felt that the best way to overcome the barrier of accessibility was by offering multi-channel access to social security and it was recognised that this is already in place
• The Local Delivery Service for Social Security Scotland is now fully operational and embedded within the local community, there are over 400 staff spread across all local authority areas in Scotland.
• The Scottish Government has committed to provide £10 million of funding over this parliamentary term to increase access to advice services to maximise incomes, tackle the poverty penalty and improve wellbeing. This will be in accessible settings, for example schools.^[30]
• While transport costs are recognised to be higher in island communities, we do not believe that mitigating this via BSF would be appropriate. We have considered this but it would be complex to administer and would not be in line with the approach taken to other social security payments that we deliver. As BSF is an ongoing entitlement, the amount paid would need to fluctuate where a recipient moved in to or out of an island community and this would increase the risk that overpayments would be made. We also noted that through the National Plan for the Islands,^[31] actions have already been identified to tackle the higher costs of living, including fuel and transport as well as to drive inclusive and sustainable economic growth. These actions are likely to have a more direct and positive impact on tackling the cost of living for all residents in Island communities.
• The policy changes we are making will further align eligibility and procedural rules for BSF with SCP and BSG. This will help support the potential future automation of the benefits as well as make it easier for individuals to understand what they are entitled to. One stakeholder indicated that by further aligning BSF with BSG and making it easier to receive BSF, this could help take-up.

Stigma

• Raising awareness about the positive socio-economic impacts for local businesses and the wider community benefits from maximising incomes from social security, was seen as one way in which to reduce stigma.
• The Charter for Social Security Scotland^[32] already commits us to:
  • promoting a positive view of social security, explaining it is a public service to be proud of – a human right there for all of us who need it;
  • publicly challenging the myths and stereotypes about social security to help reduce stigma and negativity; and
  • changing the language on social security - introducing more positive words to describe the service and the people who use it.
• Social Security Scotland have engaged with food retailers across Scotland to help raise awareness of BSF and the benefits it can have for their business. This has led to various initiatives where Social Security Scotland have worked in partnership with food retailers to promote BSF.
• One stakeholder noted that BSF helps to address stigma and improve the health and wellbeing of pregnant people and children. They also felt that BSF could contribute to better educational outcomes.
• We remain committed to moving to a cash payment for BSF. We are currently scoping when this can be done and are confident we will be able to make this change in the future. However, operating under an increasingly challenging programme of delivery which will see us deliver several new benefits, including Carer Support Payment, in the coming years means we are not able to move to a cash payment in 2023-24.

Cost of living

• One stakeholder suggested that we consider an uplift for island communities. We have considered this, but this would be complex to administer and would not be in line with the approach taken to other social security payments that we deliver. As BSF is an ongoing entitlement, the amount paid would need to fluctuate where a recipient moved in to or out of an island community and this would increase the risk that overpayments would be made. We also noted that through The National Plan for Scotland’s Islands,^[33] actions have already been identified to tackle the higher costs of fuel, transport and housing as well as to drive inclusive and sustainable economic growth. These actions are likely to have a more direct and positive impact on tackling the cost of living for all residents in Island communities.
• We also heard from one stakeholder that the recent Island Communities Cost Crisis Fund was very well received and feedback was highly positive. For many, these payments were used to pay essential bills and help reduce debts. For some others, they were able to buy better quality foods and expand the range of foods in their diets. They felt that BSF payments also free up some monies within family budgets to be spent on other essential items, thus helping to reduce the risk of new or increasing debts, or the amount of debt already incurred, and to introduce new and different food types and better quality of foods into diets. This echoes the findings of the evaluation of BSF which suggested that the payment helps people buy a greater quantity (and quality) of healthy foods than they could without the benefit and that for some it frees up money for costs such as household bills.^[34]
• One stakeholder fed back that while it may not on it’s own fully mitigate the higher cost of living in the islands, the additional support provided by BSF would be welcomed by eligible families.

Other

• To mitigate the risk of potential abuse, the regulations ensure that where anyone other than the pregnant person is receiving BSF and an application from the pregnant person is received, Social Security Scotland will end the existing claim and pay the pregnant person instead. Where multiple applications are received in relation to a pregnancy but no application is made by the pregnant person themselves, the amendment regulations will provide Scottish Ministers with the power to decide who should be awarded BSF, having regard to the circumstances of the pregnant person. Furthermore, when either the partner of the pregnant person or the individual that the pregnant person is dependent upon or the partner of that individual is being paid BSF, the regulations state that they are only entitled if they are using BSF for the benefit of the pregnant person. If it is established that they are not using BSF for the benefit of the pregnant person, they are not eligible to receive BSF.
• Furthermore, allowing Scottish Ministers to pay whoever they consider appropriate on behalf of an entitled person will mean that where it is established that the individual who is receiving BSF on behalf of an entitled child is not using BSF for the benefit of the child, payments can be made to another appropriate person instead so that the entitled child continues to benefit from BSF.

Is A Full Island Communities Impact Assessment Required?

You should now determine whether, in your opinion, your policy, strategy or service is likely to have an effect on an island community which is significantly different from its effect on other communities (including other island communities). To form your opinion, the following questions should be considered:

Are there mitigations in place for the impacts identified and noted above from stakeholders and community consultations? (If further ICIA action is not required, complete the section below and publish).

• Yes

Does the evidence show different circumstances or different expectations or needs, or different experiences or outcomes (such as levels of satisfaction, or different rates of participation)?

• No

Are these different effects likely?

• n/a

Are these effects significantly different?

• n/a

Could the effect amount to a disadvantage for an island community compared to the mainland or between island groups?

• n/a

If your answer is ‘no’ to the above questions, please complete the box below.

If the answer is ‘yes’, an ICIA must be prepared and you should proceed to Step 5.

A Full Islands Community Impact Assessment Is Not Required

In preparing the ICIA, I have formed an opinion that our policy, strategy or service is not likely to have an effect on an island community which is significantly different from its effect on other communities (including other island communities). The reason for this is detailed below.

While some impacts unique to the islands were identified, there are existing mitigations in place to address these. However, many other key barriers effecting the Islands, also impact mainland Scotland (albeit, in different ways to the islands), such as; cost of living and stigma. Therefore, they are not unique to the Islands. The evidence does not suggest that any new negative impacts will be created by the changes we are introducing.

The evidence does not suggest that the effects of the regulation amendments will differ significantly for the islands. The key aim of the amendments is to have a positive impact across the whole of Scotland and stakeholder feedback is clear that the amendments will impact Island Communities positively. Specifically, widening eligibility and making it easier to access BSF will benefit low income families across the islands by increasing their income.

Screening ICIA completed by: Lauren James, Policy Officer

Signature and date: Lauren James, 10th November 2023

ICIA authorised by:Ian Davidson, Deputy Director, Social Security Policy

Signature and date: Ian Davidson, 10th November 2023