Pension Age Winter Heating Payment: Equality Impact Assessment

Key Findings

Protected Characteristics

Age

40. Age is a protected characteristic under the Equality Act 2010. The policy to extend PAWHP to those earning £35,000 or less is designed to provide additional support to people of pension age in Scotland, except those above the £35,000 income threshold, to help towards meeting heating costs during the winter. Therefore, this impact assessment will examine the impact of how the policy will affect this particular age group. Poverty and income inequality statistics define pensioners as adults who have reached their state pension age, with the state pension age for both men and women increasing to 66 years in the most recent reporting period of the Poverty and Income Inequality in Scotland 2021-24 statistics.^[26]

41. According to a 2023 report by Independent Age, pensioner poverty is a growing issue in Scotland, with one in seven people over state pension age living in poverty in Scotland. ^[27]

42. Similarly, the Scottish Government estimates that 15% of pensioners (150,000) were living in relative poverty after housing costs in 2020-23.^[28] Before housing costs, 17% of pensioners (170,000) were in relative poverty. Pensioner poverty rates are typically higher before housing costs than rates after housing costs, because the majority of pensioners tend to have a relatively low income but incur low housing costs as they own their home. It is therefore more meaningful to use the after-housing-costs poverty measure for comparing the standard of living between pensioners and other age groups.

43. The 2023 SHCS includes the 2023 criteria for WFP prior to the introduction of restricted eligibility, and estimates that 861,000 households were in fuel poverty in 2023. This rises by around 10,000 to 871,000 when the 2024/25 means-tested PAWHP approach is applied to the 2023 data. When applying the initial 2025/26 approach of universal eligibility through £100 payments to those not on relevant benefits to the 2023 SHCS data, we would estimate around 865,000 households to be in fuel poverty. The approach would therefore reduce the number of households in fuel poverty under that criteria by 5,000, when compared to 2023 levels using the means-tested PAWHP criteria. Analysis on the impact of the upcoming PAWHP changes on fuel poverty levels is forthcoming but it is expected that any impact on overall fuel poverty levels will be minor.

44. The 2023 SHCS found that older households (37%) have similar rates of fuel poverty to families (34%) and have higher rates than other households (32%). When considering extreme fuel poverty, the fuel poverty rate for older households was 25% compared to families (12%) and other households (19%).

45. Older people are also more likely to live in less energy efficient homes. The recent SHCS shows that older households (66.1) have lower average Energy Efficiency Rating than families (69.3) and other (adults without children) households (68.3). Poor energy efficiency is a key driver of fuel poverty.

46. According to the 2023 SHCS, 491,000 households are in extreme fuel poverty under the original WFP eligibility, prior to the introduction of means-testing. This is expected to have increased to around 501,000 households under the means-tested PAWHP for 2024/25. Conversely, we would estimate a decrease to 495,000 households under the initial, universal PAWHP eligibility. Analysis on the impact of the upcoming PAWHP changes on fuel poverty levels is forthcoming but it is expected that any impact on overall fuel poverty levels will be minor.

47. Research published by Age Scotland in 2022 suggests that 76% of older people are always concerned about paying fuel bills. According to Age Scotland, just 16% of respondents to their 2022 ‘Taking the Temperature’ survey were very satisfied that they could heat their home to a comfortable level, 30% were fairly satisfied, with 34% not satisfied they could heat their home to a satisfactory level.^[29]

48. In a poll commissioned in September 2022 by Independent Age of those over 65 with a household income below £20,000, 65% were worried they won’t be able to pay for gas, and 69% were worried they couldn’t pay for electricity. 74% admitted to cutting back on their heating, while 53% of participants also revealed that their current income negatively impacts their quality of life. ^[30]

49. Older households are less likely than families and other household types to report that their heating system doesn’t always keep them warm in winter; 18%, compared to 27% for both families and other households.^[31] These figures are similar to 2022, but represent an increase from 2019 levels.

50. Living in a cold home can be detrimental to many pensioners, due to reduced muscle mass and poorer circulation, they are not as physiologically able to keep warm during cold periods. There is also a strong relationship between cold homes and cardiovascular and respiratory disease.^[32] This can affect their immune systems which can amplify any pre-existing condition.^[33] Links between long term health conditions, poor health, wellbeing, and living in a cold, damp home is well recognised. In addition, there is also evidence on the mental health and wellbeing impacts of living in cold homes and experiencing fuel poverty, and the benefits to mental wellbeing which can be delivered from tackling fuel poverty across the age range.^[34]

51. Within our public consultation^[35], some respondents expressed concerns that older people in Scotland could receive less or lose out on funds compared to those in the rest of the UK if changes are made to the benefit in the future. Some respondents expressed concerns that targeting the benefit to those in receipt of Pension Credit could result in the exclusion of those just above the threshold to receive this benefit, but who are still in need of financial assistance.

52. Distributional analysis by the Office of the Chief Economic Advisor suggests that when compared to the qualifying benefit policy, the new policy is more generous to pensioner households with a member aged 80 or over. This is because pensioners who do not receive a relevant benefit become eligible for a £305.10 payment whereas pensioners aged below 80 only become eligible for a £203.40 payment. Compared to the universal policy, pensioner households of all ages lose by a similar amount to the average due to the introduction of the income threshold.^[36]

53. Under the previous UK system, households with individuals aged 80 and over received £300. Under the revised approach this higher payment amount has been maintained for those aged 80 and over who earn £35,000 or less. As noted in the analysis above, individuals aged 80 and over are generally more vulnerable to the effects of cold weather and may have higher heating needs due to frailty, mobility issues, or health conditions.

54. The most recent Scottish Housing Condition Survey^[37] found a strong association between fuel poverty and income, with 96% of those in the bottom income band (less than £15,000) being in fuel poverty and 58% for the second bottom band (£15,000 - £24,999). The fuel poverty rate for households earning between £25,000 - £34,999 was 23% and for those on an income band of £35,000 and £44,999 was found to be 9%.

55. Those aged 80 and over, earning over £35,000 will be impacted by the removal of the payment to this cohort. The Scottish Government recognises this and will continue to monitoring outcomes and consider future changes, within available resources, to ensure that older pensioners receive adequate support during the winter months.

56. The Government has taken a strategic decision to increase coverage, aiming to support more households in most need within a finite budget envelope.

57. The proposed extension to eligibility for PAWHP represents a significant positive policy change by restoring access to winter heating support for more pensioners, targeting those in most need in Scotland. This aligns with the principles of equality and dignity and will benefit thousands of pensioners previously excluded.

58. Given the expansion of PAWHP to people of state pension age earning £35,000 or less, this approach will have a positive impact on vulnerable pensioners. It provides an efficient means of delivering support across Scotland’s pensioner cohort; helping to mitigate the increases in energy costs over the winter months; and providing that cost-of-living support for pensioner households in most need, helping reduce pensioner poverty and supports fixed pensioner household incomes. This policy is therefore expected to have a positive impact on the basis of age.

Disability

59. Poverty rates remain higher for households in which somebody is disabled compared to those where no-one is disabled. In 2021-24, the poverty rate after housing costs for people in households with a disabled person was 23% (550,000 people each year). This compares with 17% (510,000 people) in a household without disabled household members.^[38]

60. Fuel poor households with low levels of energy efficiency are more likely to have at least one member who has a long-term illness or disability (56%) when compared to non-fuel poor households in similarly inefficient homes (41%).^[39]

61. Evidence highlights that there is a relationship between long-term health conditions or disability and increasing age. The 2020 Scottish Health Survey found that the prevalence of any long-term condition increased with age, from 32% among those aged 16-44 to 68% among those 75 and over.^[40] The likelihood of being disabled/experiencing chronic and complex health conditions among those 65 and over increases with age.^[41]

62. In Consumer Scotland’s report on their findings about the impacts of energy costs on disabled people and people with health conditions, they highlight that disabled people, those with health conditions and their family carers are at greater risk of energy affordability challenges due to three linked factors:

• The high cost of energy combined with their high usage needs, especially for heating but also for a variety of other reasons related to people's individual requirements including powering medical equipment, having paid carers in the home etc
• Limited opportunity to reduce their energy use without experiencing detriment
• Having generally lower incomes and a higher cost of living

63. They also reflected that those of older age could be particularly affected because due to the intersection of their disability and age.

64. According to Consumer Scotland’s Energy Affordability Survey^[42], 68% of disabled people reported rationing their energy use, compared to 56% of non-disabled people. It was also highlighted that 41% of disabled people found it difficult to keep up with their energy bills in comparison to 24% of non-disabled people.^[43]

65. Within our public consultation, some respondents suggested that eligibility for PAWHP could be extended to adults with disabilities who are below pension age. These respondents highlighted that those with disabilities could benefit from support with heating costs, as they often need to maintain a higher household temperature and are likely to spend longer periods of time in their home.

66. Similarly, many responses to our Experience Panel survey on PAWHP suggested that a payment should be extended to adults with disabilities, as they may be affected by cold weather due to their condition or may spend longer periods within their home due to limited mobility, resulting in greater heating costs. Respondents also noted the additional costs associated with running healthcare equipment for disabled people.^[44]

67. Published data relating to disability of WFP recipients is not available. However, people in receipt of disability benefits have a higher Pension Credit income threshold than those without, and their disability benefit is not considered as income in the test for Pension Credit. So people in receipt of disability benefits can still claim Pension Credit - and therefore be passported to claim PAWHP - on higher incomes than those not in receipt of disability benefits. This is reflected in analysis undertaken by the Office of the Chief Economic Adviser which indicates that 25% of State Pension recipients in Scotland claim one of the disability benefits: Attendance Allowance, Disability Living Allowance or Personal Independence Payment, and 62% of these also claim Pension Credit in Scotland, meaning those with a disability are more likely to continue to receive PAWHP than those without. Under current levels of Pension Credit take-up, around 66% of people on disability benefits and 93% of people not on disability benefits are not entitled to PAWHP under the restricted eligibility.^[45]

68. Distributional analysis suggests households with a disabled member benefit slightly more than the average household in comparison to the qualifying benefit policy. However, the impact is broadly similar to the average household when compared to the universal policy which was in effect before 2024.

69. By extending eligibility to PAWHP for those pensioners earning £35,000 or less, among others, disabled people on the lowest incomes living in households of greatest need will once again receive this guaranteed annual support. This policy is therefore expected to have a positive impact on the basis of disability.

Sex

70. Sex is a protected characteristic under the Equality Act 2010, meaning policies should not unfairly advantage or disadvantage men or women.^[46] As the PAWHP is targeted at pension age individuals, it is necessary to consider sex-based differences in life experience expectancy, income, and financial vulnerability.

71. Research shows us that female pensioners are more likely to live in poverty than male pensioners. This could be as a result of having fewer years of employment due to caring responsibilities and greater likelihood of lower paid and part-time work.^[47] In 2021-24, 23% of single female pensioners (60,000 women each year) were in relative poverty after housing costs, compared to 18% of single men.^[48]

72. Healthy Ageing in Scotland’s (HAGIS) Pilot Survey^[49] notes a substantial amount of older people live alone, with women more likely to live in a single household (44%) than men (30%). This means that men may have greater opportunity to share the responsibility for heating bills whereas more women will be solely responsible for heating their own home.

73. Since 2008 there has been a gradual increase in the proportion of adults reporting living with a long-term health condition, slightly more pronounced for women (42% in 2008 and 52% in 2022) than for men (38% in 2008 and 45% in 2022).^[50] Women were more likely than men to report having a limiting long-term condition (42% and 32% respectively). However, women tend to live longer. The most recent statistics tell us that the life expectancy in Scotland for men is 76.5 and 80.7 for women.^[51]

74. WFP statistics suggest that 54% of those who received a WFP in Scotland in 2023-24 were female, and 46% were male.^[52] Given the current take up of Pension Credit, 84% of women receiving a WFP are expected to have lost entitlement under the restricted eligibility criteria, compared to 91% of men.

75. Distributional analysis of the latest PAWHP policy suggests that compared to the qualifying benefit policy, single female pensioner households gain the most as a share of their income (0.40%) as they tend to have lower average incomes. Compared to the universal payment which was in effect before 2024, single male pensioner households are likely to lose the most as a share of their income (-0.14%) as they have a higher chance to see the payment recovered through the tax system.

76. PAWHP to pensioners earning £35,000 or less will ensure that pensioners, including those on the lowest incomes receive guaranteed annual support with their heating bills, regardless of their sex.

Gender reassignment and sexual orientation

77. The 2022 Census found that there were 19,970 trans people in Scotland. This is 0.44% of people aged 16 and over.^[53] For those 65 and over, the 2022 census found that 1190 people were trans or had a trans history.^[54]

78. When considering access to benefits, we recognise that a requirement for an individual to provide their gender when making an application may be a potential barrier to trans people and those who identify as non-binary. Non-binary people in particular can be excluded if individuals are asked to tick a box to indicate their gender and only binary options are available. This was reiterated by LGBTI youths throughout previous Scottish Government consultation engagement for CWHA - those who had undergone gender reassignment discussed feelings of being ‘outed’ by such processes as they had to reiterate that they had changed gender.^[55]

79. The Scottish Trans and Non-Binary Experiences Summary Report 2024^[56] reported key findings on socio-economic issues for trans and non-binary respondents to their self-selection survey. The survey asked about the cost-of-living crisis and access to benefits for trans and non-binary individuals aged 16+. The survey reported that 33% of respondents were claiming benefits. A majority of respondents (75%) felt their trans status, history or gender identity had not made it harder to receive benefits. But 7% felt it had, and 18% were unsure. In relation to the cost of living, the report also found that 52% of respondents said that rising costs had caused them to need to make decisions between essential household purchases and purchases relating to their transition.

80. The report also highlighted challenging experiences for trans and non-binary people trying to access DWP benefits, particularly around their records being deemed sensitive. The report outlined that due to ‘badly designed’ systems within DWP/HMRC restricting access to trans history information, this can lead to difficulties getting help with benefit claims and tax issues as well as failure in automated checks.

81. Evidence provided by Social Security Scotland client diversity and equalities analysis^[57] demonstrated that trans clients had a slightly lower approval rate for benefits than clients who were not trans across all benefits. However, there was some variation in approval rates across specific benefits. For ‘Best Start Grant and Best Start Foods’ and Scottish Child Payment, approval rates were 51% and 75% for transgender clients, compared to 62% and 81% for clients that were not transgender. In contrast, the Adult Disability Payment, clients that identified as transgender had a higher approval rate at 63% compared to clients that did not identify as transgender at 55%. Although there were larger differences in approval rates for other benefits, the number of transgender clients were too small to make reliable comparisons of approval rates.

82. The data shows that it is evident there are some barriers faced by clients who are non-binary or trans when accessing and claiming benefits. When Social Security Scotland deliver PAWHP from 2025/26, it will remain an automated payment for the vast majority of eligible recipients and therefore very few people will need to make an application. Where applications are required, a person will not be required to provide their gender. However, anyone that does apply is asked to voluntarily provide this information for statistical purposes only.

83. The design of our systems and the training of our staff will ensure that regardless of who the applicant or client is, they will be treated respectfully. Agency staff will be recruited and trained to embody values of dignity and respect and all training for new staff will include LGBTI awareness and be underpinned by human rights principles.

84. We do not anticipate anyone to be negatively impacted by the revised eligibility for PAWHP on the basis of gender re-assignment or sexual orientation.

Religion or belief

85. We have not identified any particular barriers resulting from our policy approach which may affect people with the protected characteristic of religion or belief.

Pregnancy and maternity

86. As our benefit will be paid to people of pension age, we do not believe pregnancy and maternity status to be a significant factor for our target group.

Race

87. Race is a protected characteristic under the Equality Act 2010.^[58] The introduction of the revised PAWHP should be assessed for the impact on the diverse racial communities living in Scotland.

88. At the time of the 2022 census, 87.1% of Scotland’s population identified as “white” “Scottish” or “Other British”, while 12.9% identified as belonging to another ethnic group.^[59] In 2022, 5% of Scotland’s population communicated in a “main language” other than English.^[60]

89. Over the five year period from 2018-23 people from non-white minority ethnic groups were more likely to be in relative poverty after housing costs compared to those from the ‘White - British’ and ‘White - Other’ groups. The poverty rate was 50% for the ‘Asian or Asian British’ ethnic groups and 51% for ‘Mixed, Black or Black British and Other’ ethnic groups (no population estimates available due to the small sample). The poverty rate amongst the ‘White - Other’ group was 22% (80,000 people) and that of the ‘White - British’ group was 18% (840,000 people).^[61]

90. Research indicates that people from various ethnic minorities are more likely to experience health conditions that require a greater need for household heat, and so are at greater risk of higher levels of fuel poverty.^[62]

91. Pensioners from Black and Asian communities are around twice as likely as white pensioners to be living in poverty, with 33% Asian, and 30% Black pensioners living in poverty, compared to 16% white pensioners.^[63]

92. Based on data from the 2022 Census for households, for those aged 65 and over, minority ethnic groups such as African (African, African Scottish or African British), those of mixed or multiple ethnic groups, and White (Gypsy/Traveller) are more likely to have no central heating. Minority groups such as White (Gypsy/Traveller), Caribbean or Black, and African (African, African Scottish or African British) were more likely to have electric central heating, while those with mixed or multiple ethnic groups, Caribbean or Black, and White (Gypsy/Traveller) were more likely to have two or more types of central heating. The census data suggests that the minority ethnic groups White (gypsy/traveller), White Other (including Irish, Polish and Other White and Other White British), and those of mixed or multiple ethnic groups, are less likely to have gas central heating.^[64]

93. Our PAWHP will ensure that pensioners in ethnic minority households, including those living on the lowest incomes are supported to meet some of their heating costs during the winter months, regardless of central heating source.

94. When considering the Gypsy/Traveller community, Gypsy/travellers are more likely to have one or more long-term health conditions. 37% reported at least one health condition, compared to 30% of the population as a whole, and are twice as likely to report three or more health conditions (6% compared to 3% among the rest of the population).^[65]

95. The 2022 Census results show that, where the household reference person is aged 65 or older, 4% of the White: Gypsy/Traveller community have no central heating, in comparison to 2% respectively for all other households^[66]. In relation to gas central heating, 62% of the White: Gypsy/Traveller community have gas central heating in contrast to all other households at 73% respectively. Those relying on off grid gas are likely to incur higher costs.

96. Within our PAWHP Experience Panel survey, some respondents highlighted that groups such as gypsy/travellers may need additional support with heating costs due to their living condition or type of housing.^[67]

97. Similarly, within our public consultation some respondents emphasised that many within the gypsy/traveller community do not have access to a bank account. Respondents highlighted the importance of flexible payment arrangements, to ensure that this group is not unfairly disadvantaged.^[68]

98. We recognise that the payment method will be important for some people and particularly gypsy/traveller communities. Payments can be made in a range of ways - into a UK bank or building society account or into someone else’s account that they can access, or through using i-Movo (New Payment Exception Service) which is a secure digital voucher system that can be delivered to individuals in various media formats (SMS, email). These can be redeemed at PayPoint outlets across Scotland.

99. PAWHP is an automatic payment for the vast majority of clients, with an application only required in very specific circumstances. This automated approach should reduce any additional challenges to accessing this benefit.

100. Furthermore, Social Security Scotland will create a bank of PAWHP stakeholder resources and content, in accessible formats, available to stakeholder organisations, to distribute to people in local communities. The languages we proactively translate materials into were selected through stakeholder consultation. These are: Arabic, Farsi, Gaelic, Kurdish Sorani, Lithuanian, Polish, Romanian, Russian, Slovak, Traditional Chinese, Ukrainian, Urdu, BSL. Benefit information is also available in Easy Read format. We can translate into other languages and formats on request, including Braille.

101. Social Security Scotland will produce communications materials in other languages on request. In some circumstances, printed marketing materials may not be the right way to engage with these communities and, where this is the case, we will provide an engagement approach through the Strategic Stakeholder Engagement and Partnership and Events teams.

102. National Carer Organisations advocated in their consultation response for accessible resources to be produced to benefit ethnic minority groups, recommending the Minority Ethnic Carers of People Project (MECOPP) briefing on Producing Accessible Information for BME Communities as a useful tool for this.

103. While it is clear that older people from ethnic minority communities experience numerous barriers, we have not identified any particular barriers resulting from our policy approach which may affect people based on race.

104. The PAWHP payment for pensioners earning £35,000 or less will benefit pensioner communities in Scotland, including those living on the lowest incomes.

105. We have not identified any particular barriers resulting from our policy approach which may affect people with the protected characteristic of race.

Marriage and Civil Partnership

106. Marriage and Civil Partnership is a protected characteristic under the Equality Act 2010. ^[69] We should therefore consider the different impacts of introducing PAWHP depending on people’s marriage or civil partnership status.

107. In data published for 2019-22, married adults were the least likely to be in poverty.^[70] Analysis from Age UK shows that single female pensioners (27%) have a much higher risk of being in poverty than single men (23%), and pensioner couples (13%).^[71]

108. Using the Family Resources Survey data, approximately 40% of those who received a WFP in 2022-23 were single. Those in a couple (96%) were more likely to lose out under the restricted PAWHP eligibility than single people (74%). This may be partly explained by the fact that, since 2019, mixed-age couples (where one person is below state pension age) can no longer apply for Pension Credit. Analysis suggests that some of these mixed-age couples are not able to get Universal Credit and therefore miss out on PAWHP under the restricted eligibility criteria.

109. The revised eligibility for PAWHP would therefore positively impact some mixed-age couples, ensuring a guaranteed PAWHP payment for those who have an income of £35,000 or less who may otherwise miss out due to the restrictions on claiming Pension Credit when in a mixed age couple.

110. As noted previously, analysis carried out by the Scottish Government on the impact of the universal PAWHP showed that as a proportion of income, there is a slightly greater benefit for single occupancy households. This is because single occupancy households have lower average household incomes.

111. In our revised approach to PAWHP, to deliver PAWHP as a household payment, entitlement for pensioners are determined and payments made on an individual basis. The amount an individual pensioner will get paid depends on their household circumstances. The payment rates will be £101.70, £152.55, £203.40 or £305.10 for individuals. Generally a typical household where the older person is under 80 will receive £203.40 and a household with a person aged 80 or over will receive £305.10.

112. We have not identified any particular barriers resulting from our policy approach which may affect people with the protected characteristic of Marriage and Civil Partnership.

Recommendations and Conclusion

113. Based on the evidence collated, it is clear there are a number of factors which make pensioners with protected characteristics more likely to need additional support with their heating expenses, including low levels of income, higher energy needs because of a health condition or disability, as well as lower quality of housing, or lack of central heating. Energy prices continue to be a key driver of fuel poverty, and PAWHP will provide pensioner households in most need with a valuable contribution towards meeting those costs.

114. This approach recognises that there are people who are above the income threshold for relevant benefits who require additional support with their heating expenses and thus ensures a higher level of support can be provided to those with an income of £35,000 or less.

115. This approach will have a positive impact for many pensioners. It provides an efficient means of delivering support across Scotland’s pensioner cohort; mitigating the increases in energy costs; and providing cost-of-living support for pensioner households at most risk of fuel poverty, including those living on the lowest incomes, helping towards work to reduce pensioner poverty and support to fixed pensioner household incomes.

116. Whilst eligibility to PAWHP for those earning £35,000 or less will not tackle fuel poverty alone, it will help towards the costs of keeping warm in the winter months when heating bills are higher. Our PAWHP will sit alongside other Scottish Government support such as energy efficiency schemes which aim to tackle poor energy efficiency as a driver of fuel poverty. PAWHP will provide reassurance to older people on the lowest incomes that they will receive support to help towards the costs of keeping warm in the winter months when heating bills are higher. This is particularly important given the significant increase in the cost of living.

117. The Social Security (Scotland) 2018 Act established the Scottish Commission on Social Security (SCoSS), an independent expert body that scrutinises the Scottish social security system (including benefit regulations) and holds Scottish Ministers to account. Section 97(2) and (3) of the Social Security (Scotland) Act 2018 requires Scottish Ministers to inform the Scottish Commission on Social Security (SCoSS) of these proposals in the form of draft regulations. The Scottish Ministers provided draft regulations to SCoSS shortly before laying this draft instrument in compliance with section 97(2).

118. Due to the late change in policy from the UK Government, and the lack of prior consultation with the Scottish Government, this instrument must be laid as a matter of urgency in order for payments to be made on time this winter, and it has therefore not been possible for SCoSS to have the appropriate amount of time to scrutinise and publish a report on the regulations before we lay the regulations in Parliament.

119. As such we are laying this draft instrument as well as a statement explaining why the Ministers consider it appropriate to lay the regulations without a report from SCoSS having been prepared. The Scottish Ministers will consider that report when it is published. SCoSS has been informed of the urgent nature of these regulations, resulting from the UK Government’s recent decision to expand eligibility to WFPs, and it is content to scrutinise the regulations before and after the regulations are laid.

120. The Social Security (Scotland) Act 2018 also places a duty on the Scottish Ministers to publish an annual report on the performance of the Scottish social security system during the previous financial year. The report is to describe what the Scottish Ministers have done in that year to meet the expectations on them as set out in the Charter.

121. As with all social security benefits, we will carry out an evaluation following the delivery of the benefit and continue to investigate ways of making improvements.

122. The Scottish Government will put in place a monitoring and evaluation plan for PAWHP. Monitoring the impact of PAWHP will be a continuous process and where any unintended consequences are identified, we will consider what steps can be made to minimise any negative impact.

123. We will collate management information to monitor the characteristics of recipients and will undertake qualitative research to test whether PAWHP is meeting its policy intentions. This will inform any future consideration of variations to policy or delivery arrangements.