Winter Heating Payment (Low Income) (Scotland): child rights and wellbeing impact assessment

How have you consulted with relevant stakeholders, including involving children and young people in the development of the policy/measure?

17. Throughout the consultation period we have engaged and had feedback from stakeholders who represent and work with children and disabled people directly including Child Poverty Action Group Scotland, Save the Children, Family Fund, One Parent Family Scotland and Inclusion Scotland.

Consultation

18. In consulting on the proposed introduction of LIWHA the following question was specifically posed to respondents: ‘Please set out any information you wish to share on the impact of LIWHA on children’s’ rights and wellbeing’

19. A total of 27 respondents provided an answer to this question^[8]. Key themes in these responses in regards to children’s rights and wellbeing-specific impacts were:

• Increase in income
• Improving the outcomes (health, wellbeing, development) of children in Scotland
• Families potentially losing out through change from CWP to LIWHA
• Introduction of a ‘qualifying week’ meaning families with a new-born could miss out

20. Responses to the public consultation on LIWHA (now WHP) indicated that the introduction of the benefit would have a positive impact on children and respondents acknowledged the introduction could provide an increase in income for eligible families, improving the health, wellbeing and development of more children in Scotland.

21. Whilst concerns were raised around the value of the payment not being sufficient, in particular for children who have a disability with the Poverty & Inequality Commission for Scotland believing the amount of assistance was not high enough to fully ensure disabled children’s right to ‘enjoy a full and decent life’, in general respondents thought it would have a positive effect. Family Fund supported the introduction saying ‘We believe that LIWHA will enable more children to enjoy their right to an adequate standard of living that is good enough to meet their physical and social needs and support their development. We also believe that it will support children to enjoy their right to the best possible health’.

22. Following the analysis of the consultation responses we considered a number of options including increasing the value of the payment and extending eligibility to a variety of groups. Our considerations are set out below:

Value of the Payment

23. The consultation proposed a single annual payment of £50, equivalent to the value of two CWPs. Many consultation respondents thought this should be higher; suggestions tended to range between £75 and £100. However, this would increase the forecasted annual expenditure from £20 million to between £30 million and £40 million, assuming the same number of recipients of qualifying benefits.

24. Any increase in value of the payment would affect the annual expenditure and such an increase at this time would not be affordable. We have therefore not made any changes to the value of the payment.

Qualifying Benefits

25. Many respondents to the consultation suggested extending eligibility to include other qualifying benefits such as those paid to carers and people with disabilities, including expanding eligibility to those in receipt of PIP and DLA. Others proposed removing the requirement for receipt of premiums relating to disabilities and children in the current qualifying benefits, widening the scope to a wider group of people. Other suggestions included extending eligibility to households on low incomes who do not receive any benefits.

26. Adding to the qualifying benefits for WHP could extend eligibility to potentially a significant number of people who are not necessarily on a low income and who could be in employment. We could not therefore deliver WHP to an extended group of eligible clients and still launch the new benefit by winter 2022-23 as we have committed. Due to the overlap between the current eligibility for CWP and those households who have need for an enhanced heating regime, it is considered that the present proposals are appropriate to ensure that the new payment is targeted to individuals who are most in need. Any increase in value would significantly increase the funding required and this needs to be considered against affordability and value for money.

27. We recognise that the costs associated with heating homes has increased significantly since the initial development of WHP policy. This policy aims to mitigate some of the challenges presented by the volatile winter energy costs for vulnerable households and also to help alleviate poverty and inequalities. The current record rise in global gas prices which has seen wholesale prices increasing significantly in the last year, heightens the risk that despite this financial support, there will be an ongoing need to support those at risk of, or in, crisis.

28. The Scottish Government’s annual expenditure on WHP will exceed the funding provided for CWP through the Block Grant Adjustment (BGA). We have made a choice to invest over and above the corresponding level of funding that we are forecast to receive from the UK Government and this therefore limits the scope for additional increases to the value or frequency of payments from within our fixed budget. We do not, therefore, intend to change the eligibility criteria.

29. We also considered the length of time between the qualifying week, when eligibility will be assessed, and the payment. Concerns were raised that the proposed qualifying week in September was too far away from when the payment would be received in February. Respondents also highlighted that a payment earlier in the winter may be preferable. As a result of these considerations we have moved the qualifying week from the proposed date in September to November and have committed to undertaking further work following the launch of the benefit to explore the feasibility of bringing forward the payment date in future years.

30. In replacing CWP with WHP we must ensure that our approach meets the commitment, that people who previously would have received a CWP (should the weather conditions have been met) continue to receive winter heating support with minimal disruption.