Carer support payment priority improvements: impact assessment updates

Consumer Duty Assessment

Introduction

The Consumer Scotland Act 2020, which came into force on 1 April 2024, established a Consumer Duty on public bodies to improve the extent to which consumers are considered in decision making. As this was not a duty during the introduction of Carer Support Payment there is no previous assessment to update.

The Consumer Duty considers the impact on consumers of strategic decisions, in this case the introduction of legislation. The Carer Support Payment priority improvements aim to introduce new forms of support, widen eligibility to existing support, and change elements of how an existing benefit is paid. We expect this to mainly impact carers, and welfare advice services as carers adapt to the new eligibility requirements, and consider applying for the new support.

To gather views the public consultation^[91] on Carer Support Payment (formerly known as ‘Scottish Carer’s Assistance’) was open for 12 weeks, from 28 February until the 23 May 2022. The consultation invited views on any impacts of Carer Support Payment on individuals and businesses. A total of 192 responses to the consultation were received, 151 responses from individuals with 41 from organisations.

Impacts

Carers

As the improvements widen eligibility, extend support after a bereavement, and introduce new support, we expect any impact on individual consumers to be positive. The improvements increase access to support with a communication plan to help ensure individuals have clear information on what is available to them. Delivered through Social Security Scotland built on the principles of dignity, fairness and respect at its core.

The priority improvements do not directly or indirectly limit the choices of consumers, nor do they impact the consumers’ safety or right to representation. All eligibility decisions for Social Security Scotland benefits have the same right to redetermination and appeal should they disagree with a decision.

Information on the expected impacts of each improvement on an individual’s finances is available in the Fairer Scotland Duty Assessment update.

Third Sector Organisations

As set out in the Equalities Impact Assessment for these regulations, as a general point, introducing rules which are different to Department for Work and Pensions’ intrinsically adds complexity. This increase in complexity could see an increased demand on welfare advice services.

To mitigate this we will provide clear information, communications and support in advance of the introduction of the improvements. Along with these we will host online events to inform stakeholders about the changes so they can continue to provide advice for carers. Targeted communications with carers will also aim to reduce the need for carers to engage with organisations to mitigate the potential impact.

Information on the expected impacts of each improvement on businesses can be found in the Business and Regulatory Impact Assessment section.

Summary and conclusion

Overall the improvements will have a positive impact on individual consumers who become eligible for more financial support. There is a potential negative impact on welfare advice services through increase demand on their time but mitigations will be introduced to minimise this impact. We will continue to engage with stakeholders like our Carer Benefits Advisory Group to monitor these impacts.