Scottish Welfare Fund review: final report

10. Suggested improvements to the Fund

Key points

• Suggestions for improvement from applicants, external stakeholders and local authority SWF teams focused on communication and promotion, the application form and process, timescales and administrative resources, delivery, changes to the guidance, and overall funding.
• Applicants and external local stakeholders suggested more could be done to raise awareness of the Fund, particularly among those who might be new to needing state support. The clarity, consistency and tone of communications with applicants were also seen by some as in need of improvement.
• Application forms were seen as in need of simplification. Applicants and external stakeholders also wanted all local authorities to ensure the process was accessible to all, especially those with no phone or internet access.
• Applicants and external local stakeholders wanted to see shorter turnarounds for decisions. Local authorities wanted to see more administrative funding to ensure they were able to process applications within the existing timeframes. They also questioned whether the guide timeframes should be more flexible, to allow for prioritisation within grant types.
• There was no consensus on whether there should be changes to the ways in which grants are fulfilled (e.g. cash or vouchers), but applicants suggested there could be improvements to the quality of some Community Care Grant items.
• Local authorities suggested various possible changes to the SWF guidance, including:
  • Changes to the maximum number of applications – though there was no consensus on whether these should be relaxed or tightened
  • Increases to capital and income thresholds, removal of the under 25 rate, and updates to the guidance on calculating realistic awards
  • Potential reinstatement of the reference to the Fund supporting people in 'unforeseen' crisis (though concerns about this being used to 'gatekeep' were also acknowledged)
  • General improvements to ease of use and accessibility of language (with a view to making it easier for applicants as well as local authorities).
• There was no consensus over whether the level of flexibility in the guidance was appropriate – one view was that local authorities would find it easier if it was stricter, another was that it could and should not be more restrictive given the range of needs the Fund is intended to help address.
• Current funding levels for grants were seen as unsustainable in the context of increased pressures on cost of living. Many – though not all – of the other suggested improvements were strongly linked to funding levels.
• In the light of findings in this report on differences in outcomes between local authority, there may be scope in the future to support improvement within the SWF via improvements to data collection and reporting, enhancing approaches and raising awareness of Tier 1 reviews, and considering a programme of ongoing monitoring and audit.

This chapter summarises suggestions made by applicants, external local stakeholders and local authority SWF managers and delivery teams about potential improvements to the scheme. Given the variations in specific practice between areas, discussed in earlier chapters, it is likely that some of these suggested improvements will be more relevant to some local authorities than others. However, some are relevant at a Scotland-wide level – for example, those relating to the eligibility criteria and the guidance.

The chapter ends by drawing together findings from across the report on differences between local authorities, to make some suggestions about possible approaches to audit and review of the SWF in the longer-term.

Communication and promotion

Among the applicants interviewed for this review, suggestions for improvement focused particularly around awareness raising – of the scheme itself, the right to request a review, and the eligibility criteria and evidence required to support applications. As discussed in earlier chapters, there was a perception that applicants had only found out about the scheme by chance, particularly when they were new to needing state support with their finances. Both applicants and external local stakeholders felt there could be more promotion of the scheme, particularly to groups who might be less familiar with the system (including those in work).

In addition to awareness raising, applicants also suggested that communications around the SWF could be improved in general. As discussed, applicants were not always clear whether or not they were eligible or what information they needed to provide to demonstrate this, while awareness of the right to review was very variable, as discussed in chapter 8. Applicants suggested there could be better communication of all these elements.

As discussed, although there were examples of very positive experiences of how the SWF team communicated with them, where applicants reported more negative experiences, particularly in terms of their perceptions of how they were spoken to on the phone, this could have a major negative impact on their overall experience and willingness to apply in future. It was suggested that there might be a need for further staff training around mental health issues and how to speak to people who struggle to communicate clearly by phone.

There was also a desire among applicants for more consistent communication of what to expect during the application process – including confirmation of application receipt and updates on the application process and likely timing (an 'application tracker' was suggested). Finally, applicants felt the reasons behind decisions could be communicated more clearly.

These suggestions around communication and promotion were all echoed in interviews with external local stakeholders. In addition, there was a desire for more communication with the third sector both in general and in relation to individual applications where they had supported clients to apply, so that they could continue to support them around the outcome.

Application form and process

As discussed in earlier chapters, there were comments from across all groups of interviewees about the application forms used for the SWF. Applicants and external stakeholders in particular felt the application forms needed considerable improvement to shorten and simplify, reduce repetition, and remove questions that could be perceived as intrusive. It was suggested (by an applicant) that bank statements should not be required, as these can be hard to get hold of and act as a barrier to applying.

Applicants and external stakeholders also commented on the need to ensure the process itself was accessible to all – especially those with no phone or internet access, who might still need to be able to apply in person. The SPSO has also highlighted access issues arising from inconsistency in whether councils have a freephone number available, noting that they regularly receive calls from applicants who cannot contact the council because of this. Stakeholders in prisons suggested it would be better if people in or leaving prison were able to apply online, though they recognised this was a wider issue rather than one that only impacts the SWF.

Suggestions about accessibility also related to the support available to applicants. One suggestion from an external local stakeholder was that support from an advocacy organisation should be built into the process. Applicants also mentioned wanting more phone and/or face-to-face contact with the SWF team, to be able to provide the full picture (as discussed, the emphasis on phone applications/follow-up varied between areas).

Timescales and administrative resources

Both applicants and external local stakeholders wanted to see shorter turnarounds for decision-making and, for Community Care Grants, delivery of grants.

As discussed in chapter 4, local authorities were strongly of the view that administrative funding needed to be substantially increased to enable them to process more decisions within the existing timeframes. This view was echoed in interviews with external local stakeholders, who also felt that more local authority SWF staff were needed in order to reduce timescales for decisions and make it easier for applicants to get through by phone.

Local authority interviewees also raised questions around whether the guide timeframes needed to be as fixed, or whether there could be more flexibility to enable greater prioritisation, particularly between Community Care Grant applications, to help local authorities manage pressures on staff. However, given applicants' accounts of the impacts of delays, any such flexibility would need to be very carefully managed.

Delivery

As discussed in chapter 7, there was no consensus among applicants or external local stakeholders on the how much choice participants should have around how grants are fulfilled. This lack of consensus was reflected in external local stakeholders' suggestions for improvement – it was suggested that both types of grants should always be cash, that it was be better for applicants to pick Community Care Grant items from a fixed list of options, and that Crisis Grants should be given as vouchers.

Applicants also suggested that there could be improvements to the quality of some items provided through the Community Care Grant, particularly with respect to flooring and carpets and soft furnishings.

Changes to the guidance

Changes to the SWF guidance were primarily discussed in interviews with local authority managers and teams, although suggestions for improvement from applicants and external local stakeholders also sometimes related to elements of the guidance.

Overall balance between fixed rules and flexibility

Overall, the guidance was viewed very positively – it was referred to as a 'bible' for decision-makers. However, different views were expressed by local authority managers and staff on whether the level of flexibility in the guidance was appropriate or should be reduced. One view was that stricter or more specific guidance would be helpful to local authorities:

"Generally, LAs want tight, clear guidance, partly because if people are disgruntled then we can get complaints from MSPs and MPs - where we have discretion. We would rather all LAs were doing the same thing"

(Local authority manager 24)

However, others felt that the guidance could or should not be any more restrictive, even if this was sometimes challenging for staff, since the range of problems the Fund was set up to help was wide and discretion was necessary to enable local authorities to meet varying local needs:

"I guess the guidelines have to be wide and varied but it doesn't do anything for the staff to have to make that decision."

(Local authority manager 28)

As discussed in chapter 2, there were various suggestions from local authorities and external stakeholders (including the SPSO) around alternative ways of improving consistency of process between areas, including:

• Enhanced centralised support for decision-makers, including more knowledge sharing and/or joint sessions between areas
• More frequent updates to the guidance (the SPSO suggested this should be annual, and should also be more responsive to emergent issues, like cost of living increases, or clarification of what should be classed as 'exceptional circumstances' when the context changes, as it did during the pandemic)
• Centralisation of some administrative functions (specifically suggested in relation to a national database to help identify potential cross-local authority fraud), and
• Budget increase to reduce discrepancy in priority levels.

Maximum number of applications

Again, managers in different local authorities expressed opposing views on this. On the one hand, it was suggested that allowing a couple to apply to the Fund six times a year (three times each) was too much given Crisis Grants were intended to meet one-off needs. On the other, there was a view that people should be allowed to apply more often, in recognition of the fact that the cost of living crisis was creating recurrent 'crisis' situations for more people – a view that was echoed in suggestions for improvement from applicants and external local stakeholders, who suggested the maximum should be increased.

At the same time, while local authorities acknowledged that the guidance does allow for local discretion to pay more than three grants when applicants are in exceptional circumstances, one view was that the rules on this should be clearer, to avoid discrepancies in approach to repeat applications between areas.

Capital and income thresholds

Local authority managers commented that the capital thresholds set out in the guidance had not been reviewed since the Fund started in 2013. For Community Care Grants in particular, the level these were set at was viewed as too low to allow someone to furnish a home to an adequate standard. Other suggestions included aligning the income threshold with the higher threshold set for SISGs and removing the need for people to use their available overdraft before applying for a Crisis Grant, as it was viewed as counterintuitive to require someone to go into overdraft if they had no means of getting out of it again. These suggestions were often linked with a perception that there was a growing group of 'working poor', whose incomes were inadequate to cover the rising cost of living but who could not currently apply to the Fund.

It was also suggested (by local authority and external local stakeholders) that the under 25 rate of payment for grants should be removed, since goods cost the same regardless of age.

Similarly, the SPSO suggested that the guidance on calculating realistic awards needed to be updated, since the rates suggested for Crisis Grants are unlikely to meet the increased costs of gas and electricity. This was reflected in suggested improvements from applicants, who also mentioned increasing grant amounts to better match need.

'Unforeseen' crisis

Local authority managers noted that an earlier iteration of the statutory guidance had referred to Crisis Grants being for those in 'unforeseen' crisis. This was subsequently removed, as there was a perception it was associated with inappropriate 'gatekeeping' of the Fund. While local authority managers understood the reasons for this, there was nonetheless a perception that this could make the Fund challenging to navigate for decision-makers – for example, if someone runs out of money because they have spent money on something that might not be viewed as a necessary item before covering their essential expenses for the month.

Accessibility of guidance

Finally, the SPSO suggested that the guidance could be restructured to make it easier to use for decision-makers, by ensuring all the information relevant to Crisis Grants was together, and similarly for Community Care Grants. A related suggestion from a local authority manager was that the guidance could be made more customer friendly, to support communicating reasons for decisions in an easily understandable manner.

Overall funding levels

Overall funding levels for SWF grants (rather than administration) were primarily discussed by local authority managers. As discussed in chapter 4, there was a strong concern that current funding levels were unlikely to be adequate in the context of increasing pressures on cost of living, which was expected to drive up demand even in areas that had historically stayed within their budget.

Both local authority and wider stakeholders raised the issue that funding levels are likely to impact on many – though not all – of the other suggested improvements above. For example, changes to capital and income thresholds or the maximum number of applications in a 12-month period would likely increase the pool of eligible applicants, with additional funding required to meet associated increased demand. Similarly, if local authorities did more awareness raising than at present, this might increase demand, which would in turn require additional funding (to the extent that this demand was from eligible applicants).

However, some of the suggested improvements – around the clarity, consistency and tone of communication with applicants, improvements to application forms, the accessibility of guidance, and enhancing support for and sharing of learning between decision-makers – are less obviously dependent on the overall level of funding for grants (although they may add to administrative costs in some cases).

Ongoing data collection, audit and review

The quantitative analysis conducted for this review has shed light on trends and patterns in the delivery of the SWF, both over time and between local authorities. However, it has also revealed the complexities of interpreting this data, particularly when consistent patterns that might help explain differences between areas are lacking. This final section of the report reflects on this, and identifies possibilities for future data collection, audit and review that might help the Scottish Government and local authorities better understand the reasons for differences in spending and outcomes. Improving ongoing data collection, audit and review could also help to support improvement in consistency of practice, while recognising and retaining appropriate local discretion.

Improvements to data collection and recording

First, it is important to acknowledge that the quality and range of data on the SWF collected by local authorities and collated by the Scottish Government far exceeds that available publicly for analogous schemes in the UK. However, there are known gaps and issues in this data that could be improved in the future, particularly relating to missing data and the collection of data on equalities characteristics of applicants. Improving the collection and analysis of this data would help further improve understanding of whether there are groups of people in need that may be missing out on support available from the Fund.

Interpreting the findings on review – and understanding why people seek review, to support discussions about consistency of decision-making – would also be helped by improved recording practices, particularly around the reasons for Tier 1 review – as discussed in chapter 8, a number of local authorities recorded all Tier 1 reviews as 'other reason'.

Enhancing future review

The evidence that was available on review indicates that there may be scope for improving the contribution the review process makes to improving practice across Scotland. In particular, local authorities that were more likely to change their decisions at Tier 1 review had fewer decisions changed at Tier 2. This may indicate that encouraging local authorities to take a robust, self-critical approach to Tier 1 review results in fewer decisions being overturned by the SPSO.

The SPSO also noted that where findings and recommendations from Tier 2 reviews are shared at senior management level within local authorities, this can help drive improvement. However, their perception (based on a recent survey of local authorities) was that there was variation in the extent to which this happened across different areas. Improving the sharing of lessons from Tier 2 review within local authorities, including with senior management, may also therefore help drive learning and improvement in future.

Similarly, raising applicants' awareness and perceptions of review might help improve the contribution of review to improving practice – interviews with applicants indicated variable awareness of review rights, alongside some scepticism about the value of the process. SPSO have also suggested that raising awareness of the complaints process in relation to SWF could have similar benefits.

Possible approaches to ongoing audit

Finally, a key challenge for this review has been how to interpret the implications of variations in data between local authorities for consistency of practice. As discretion is built into the Fund, some variation between areas is to be expected. Moreover, the patterns of local variations uncovered by the quantitative analysis were often complex. There were some patterns – for example, rural local authorities have historically tended to be more likely to underspend and to have lower than expected applications. However, these patterns were not completely consistent – there were many exceptions. Meanwhile, for other findings, there was no clear pattern – the relationship between spending levels and success rates, or which areas have more decisions changed at review, for example.

Taken together, the qualitative and quantitative data in this report indicates that a wide range of factors are likely to be impacting on outcomes across local authorities, including: level of Scottish Government grant budget and availability of local top-up funding; staff resources (administrative budget); promotion and awareness raising activities; local cultural issues around accepting help; differences in the emphasis placed on different application routes; differences in the evidence required to support applications; and differences in strictness in the application of rules in the guidance. However, these factors interact with each other and with budget and demand in different ways in different local authorities. A definitive answer to why some local authorities have lower application success rates than others is therefore extremely difficult.

At the same time, another key theme from interviews with local authority managers was that historic data – particularly on spending patterns – is not necessarily expected to be a reliable guide to what will happen in 2022/23, given the pressures on the Fund expected to result from the cost of living crisis.

With all these findings in mind, and drawing on both comments from stakeholders and the experience of the research team in conducting this review, there may be merit in the Scottish Government and its partners considering approaches to monitoring and audit to support understanding and improvement of the SWF in future. This could include:

• Monitoring of the relationship between different indicators in the data at local authority level. In other words, rather than looking at things like spend, decision outcomes and reviews separately, the Scottish Government could look at these outcomes alongside one another, so that any patterns can be identified and discussed.
• A programme of audit, to support learning and improvement. One option would be to audit a random sample of decisions, either across all local authorities or within randomly selected local authorities. However, given the findings discussed above, there may also be a case for a more targeted approach to selecting local authorities for audit in order to cast further light on some of the issues identified in this report.

Analysis of the relationships between different indicators could be used to identify patterns at local authority level that raise questions – for example:

• areas where there are low success rates and large under-spends might raise questions about whether the guidance is being applied more strictly, or about how priority levels are being set
• alternatively, areas with high success rates but low levels of applications might raise questions about levels of awareness of the scheme locally
• there could also be merit in auditing high success rate, high spend, high repeat application areas, to explore the use and impact of onward referrals in avoiding repeat crisis (while recognising the limitations on avoiding this during a time of wider economic crisis).

This audit could include a systematic review of a sample of decisions – which could then be compared across audited authorities, to assess consistency of application of the guidance in decisions – alongside discussions of specific patterns in their data with local authority teams.

Any programme of audit would, of course, require resourcing. It may be something the SPSO can play a role in, given its existing role in review. The outputs could inform not only practice in the teams that are audited, but wider guidance and training on delivery of the Fund.