Young Carer Grant regulations: consultation analysis

Applications and Eligibility

In addition to seeking general views on the impacts of the Young Carer Grant draft regulations, the Scottish Government also sought views regarding specific elements of the policy. This chapter outlines the views provided in relation to the need for annual applications, as well as eligibility as it relates to combining caring hours for more than one cared-for person, and multiple carers providing care for the same cared-for person.

Annual Applications

As the role of carers and the needs of the cared-for person are known to often change over time, the consultation document proposed that young carers would make a new application each year in order to receive payment.

Q3. Do you agree with this proposal?

	Number	Percentage
Yes	57	76%
No	15	20%
No response	3	4%
Total	75	100%

Around three quarters (76%) of respondents agreed with this proposal, with the remaining quarter split between those who disagreed (20%) and those who gave no response (4%).

While those who disagreed were asked to further explain their response, a number of those who supported the proposal overall also caveated their response. Comments from both supporters and those who disagreed with the proposal typically focused on the need to provide a reminder to claimants when it was time to re-apply and/or to keep the re-application process as simple as possible.

Some respondents requested that some form of opt-in or standard reminder be sent to claimants shortly before they need to re-apply as it was felt that many young carers would be likely to forget. This point was raised mainly by individuals, although a few organisations also felt this would be important to maximise uptake:

"I think that there should be an opt-in box for young carers to be reminded a year after they have sent the application and sent a form to get the grant, to confirm that they are still in a caring role." (Individual)

Other respondents suggested that any re-application process needed to be kept as simple as possible for claimants. It was felt that claimants should not be expected to complete the form afresh each year, but rather they could be asked to review their previous application, or have the form pre-populated from their previous application and asked to confirm that the details were still accurate. This issue was discussed mostly by organisations, however, a few individuals did also suggest the need for a simplified re-application process:

"To maximise take up, it is important that making an application is as simple as possible. Therefore we think that there should be a rapid reclaim process with a pre-populated form. There are likely to be small numbers eligible for this grant, and even fewer eligible for a second year, therefore this need not be an administrative burden." (Organisation)

One organisation suggested that local authorities may be better placed to manage and deliver the Young Carer Grant. They highlight that local authorities already hold information on the qualifying young carers, and could link this to the person being cared for, including via the Registrar, thus avoiding a new claim or reminder being sent to an existing applicant where the cared-for person has passed away. They noted that local authorities are required to satisfy statutory obligations under the Carers Scotland Act 2016, and suggested that a model delivered by local authorities would align with the Scottish Government's localism agenda and deliver effective outcomes for young carers and the public purse.

Several respondents disagreed that any re-applications should be necessary. Some of these respondents felt that, as the grant was only available to young carers for a short period of time (i.e. two to three years), it should automatically renew/cover them for this entire period without the need to re-apply. Others felt that any re-application process would put unnecessary stress and burdens on young carers as well as young carers' services and other organisations who are likely to support young carers in applying for the grant. A few also felt that the need to reapply would most likely result in discouraging some young carers from applying, and that the most vulnerable young carers may be the most adversely impacted, such as those with chaotic home lives, those not in regular contact with support services, those with literacy problems or other communication barriers:

"Don't agree, this is just another task that the young carers would have to do when they have so much already. If the grant is paid for a longer period then there is maybe an argument for this, but as its just 16-18 then no." (Individual)

"I think like Carer's Allowance it should be automatically renewed unless a Young Carer has left home/cared-for person has died. Renewal of application puts a burden on Young Carers." (Individual)

"…a system that requires a new application every year acts as barrier, disincentivises applications and ultimately reduces take-up." (Organisation)

A few respondents highlighted that young carers are often caring for someone with long-term or lifelong conditions, and therefore the situation is not expected to change. As such, they felt that annual applications were inappropriate and unnecessary, (although one respondent did suggest that it may be sensible to require new applications every two years):

"For the majority of these young carers, their caring role is for a long-term disability, mental health or addiction issue therefore it would make more sense to make new applications every 2 years." (Organisation)

One respondent suggested that, rather than requiring annual applications it may be more appropriate for young carers to make a new application only at the point their caring role changes.

A few respondents also suggested that it may be helpful for the young carer to be given the option that their local young carer service is advised of their application/need to re-apply so that they can either contribute directly to the application (if appropriate) or offer assistance to the young person in completing/confirming the details:

"We would also suggest that they [young carers] are given the option for their local young carers' service to also receive the same correspondence, so they can assist them in returning it. This could be an option provided as part of the original application." (Organisation)

Whilst not directly answering the question, one respondent again raised the issue of not accommodating young carers/families that choose home education within the eligibility criteria, suggesting this showed "a huge lack of understanding of both the roles and needs of young carers and those requiring care." (Individual)

Combining Hours of Care to Meet the Required Threshold

The consultation document acknowledges that some young carers may be providing care for more than one cared-for person. It notes that a young carer may not provide the required 16 hours average of care per week to one cared-for person, but they may fulfil this requirement by caring for more than one cared-for person. While Carer's Allowance restrictions do not currently allow adult carers to combine the hours of care provided for more than one person, the Scottish Government sought views to determine whether young carers should be able to combine hours of care provided in order to be eligible for the Young Carer Grant.

Q4. Should applicants be able to combine hours caring for more than one person to meet the required 16 hours average each week?

	Number	Percentage
Yes	75	100%
No	0	-
Total	75%	100%

There was overwhelming support for this proposal, with all respondents agreeing that it should be possible to combine hours of care.

Many respondents (both organisations and individuals) noted the carer was still providing the required number of hours, irrespective of who/how many people were being cared for. Indeed, a few suggested that it may actually be more stressful for the young carer to have responsibility to care for more than one person (meaning that they would be even more likely to benefit from the grant):

"If a young person is providing the required care hours then they should receive the Young Carer Grant, regardless if their hours are as a collective of care being provided to more than one person. In some circumstances the impact of caring for two or more people for the required care hours (16 hours) may be more challenging and complex than caring for one person for the required care hours." (Organisation)

"Young carers often care for more than one person - 16 hours is 16 hours of caring." (Individual)

One respondent suggested that if a young carer was caring for more than one person they should perhaps be given a higher financial allowance by the grant:

"It's only fair that the care being given for the required hours is recognised with a payment no matter how many people are cared for. In fact if more people are being cared for then more of an allowance should be given." (Individual)

A few highlighted that the Young Carer Grant is aimed at supporting/assisting the young carer (and not the cared-for person) and therefore the entirety of the young carer's responsibilities needed to be taken into account:

"The introduction of the young carer grant is to enable young carers towards living a fuller life beyond their caring responsibilities, therefore the totality of their caring responsibilities should be in scope." (Organisation)

Some noted that a lot of young carers provide care for more than one person, and to only allow an application based on one cared-for person would exclude/ discriminate against many young carers. A few specifically indicated that allowing young carers to combine their caring hours provided a fairer system with more equitable eligibility criteria (as compared to the Carer's Allowance):

"From the perspective of a young carer who is indeed caring at least 16 hours per week, albeit they may be caring for more than one person, it could seem perverse that despite the fact that they are still carrying out the same tasks in the same period (indeed perhaps on occasions when combined for even longer periods) with all the same demands and stresses placed on them that other young carers, have they do not get the limited support on offer via the Young Carer Grant." (Organisation)

Two respondents noted that many young carers, in addition to providing care to the cared-for person, will also take on parental responsibilities. It was felt that this was not well reflected in the draft regulations, but that this was an important element of young carers' roles which should be accounted for and included within the eligibility criteria:

"…that caring hours should include replacement parental duties which should be provided by the cared-for person. For example, a young carer taking on parental responsibilities for a younger sibling - who doesn't have a disability - because their parent is their cared-for person and is unable to provide this support for their younger sibling… the criteria should be redrafted to reflect this." (Organisation)

Other issues raised by one respondent each included:

• That it may be difficult for young carers to quantify the number of hours of care they provide, particularly where a routine has been established and the young person no longer perceives certain tasks as caring; and
• A concern that the requirement risks making 16 hours of care a target, and the grant should be more focused on the young carer's wellbeing and alleviating the young person's caring role.

Multiple Carers Providing Care for the Same Person

The consultation document noted that, as well as young carers providing care for multiple cared-for people, there is also the possibility that multiple carers could be providing care for one person and therefore multiple benefits could be sought. The document notes that there may be circumstances where a young carer is fulfilling the required 16 hours average of caring each week but another carer is in receipt of Carer's Allowance for providing care for the same cared-for person. The Scottish Government sought views on whether young carers should be eligible for the Young Carer Grant when another carer (providing care for the same person) is already in receipt of Carer's Allowance.

Q5. Should young carers be eligible for the Young Carer Grant when another carer is in receipt of Carer's Allowance for providing care for the same person?

	Number	Percentage
Yes	75	100%
No	0	-
Total	75	100%

Again, there was unanimous support for this proposal. All respondents agreed that young carers should still be eligible for the Young Carer Grant, even when another carer is in receipt of Carer's Allowance.

Similar to the comments provided at Q4, many respondents (both organisations and individuals) felt that, as long as the young carer was providing the required average of 16 hours of care per week then they should be entitled to the grant, irrespective of who else may be providing care or claiming a related benefit. They felt that the young carers were still providing a caring role/managing caring responsibilities and therefore they should be entitled to the grant:

"If a young person is providing the required care hours then they should receive a Young Carer Grant, regardless if another person is in receipt of Carer's Allowance for providing care for the same person." (Organisation)

Some respondents again noted that the Young Carer Grant was aimed at supporting the young carer and not the cared-for person or other carers who may be receiving Carer's Allowance, therefore it was important that the grant was based on the young carer's circumstances alone. Several also felt that young carers should be better recognised and supported:

"Yes because the Young Carer Grant is for that specific carer not the other carer." (Individual)

"So that the young carer is getting acknowledged for the job they do and the help they deserve." (Individual)

It was also noted that caring for someone with complex needs often requires more than one carer, and that one carer should not be penalised/excluded because another carer is already in receipt of Carer's Allowance, or indeed where another young carer already receives the Young Carer Grant. One respondent also drew comparisons with Jobseeker's Allowance, highlighting that an unemployed young carer would still be entitled to this even if another adult in the household were also claiming.

Respondents also highlighted that it would be fairer to ensure young carers are eligible for the Young Carer Grant regardless of other benefits being paid to other carers, while a few suggested this would help to simplify the system, and two also indicated that this would be more consistent with the aims of the Young Carer Grant:

"As well as this being more consistent with the aims of the young carer grant, it makes the system simpler. Expecting young people to know that someone else gets carer's allowance may be unrealistic. Removing this expectation also removes a risk of error." (Organisation)

One organisation also highlighted the significant difference in funding that is available between the Carer's Allowance (£3,359 annually) and the Young Carer Grant (£300 annually), and suggested that, if a young person is providing 16 hours of care per week then they have rights under the United Nations Convention on the Rights of the Child (UNCRC) and therefore they should not be prevented from accessing the grant. This same organisation also suggested that, the fact a young carer is required to provide care on top of that already provided by the Carer's Allowance claimant is an indication of the level of need of that cared-for person. They stressed it would therefore be unfair to deny young carers in this situation access to the Young Carer Grant simply because of the caring needs of the cared-for person, when other young carers possibly caring for those with lesser needs (i.e. perhaps only the 16 hours per week care from the young carer) would still be eligible.

Two organisations also highlighted that such circumstances (i.e. where both a young carer and a Carer's Allowance claimant are involved in the provision of care for one person) likely represent those households on low incomes and therefore have less money available to support children and young people to take part in leisure and activities that are the norm for most other children and young people. They felt that, without the Young Carer Grant, some young carers with significant caring responsibilities will, therefore, remain disadvantaged.

One individual felt that, while young carers should still be eligible for the Young Carer Grant where someone else was also in receipt of Carer's Allowance for caring for the same person, they should perhaps receive a reduced amount. They suggested they should perhaps receive half or three quarters of the full grant amount, unless certain circumstances are met, with these circumstances to be determined by the Minister. This was, however, a lone view.

Meanwhile, one organisation felt that, while young carers should remain eligible, it should be necessary to demonstrate and evidence that the young carer is providing care in addition to the other family member. They suggested that sufficient reassurance/ evidence should be provided within the application that the 16 hours per week being delivered by the young carer is indeed additional/separate from those delivered by the other carer, otherwise there is a risk of double counting.

Finally, one respondent sought clarity over what type of evidence will be required in these circumstances.