Pension Age Winter Heating Payment (PAWHP): consultation analysis

We are introducing Pension Age Winter Heating Payment (PAWHP) in winter 2024/25 as a like-for-like replacement for the UK Government’s Winter Fuel Payment. This report analyses the responses from the public consultation on PAWHP that ran between 23 October 2023 and 15 January 2024.

Impact Assessments

Q17. Please set out any information you wish to share on the impact of PAWHP on groups who share protected characteristics.

Just under one fifth of respondents answered Q17. Most prevalent in comments were respondents who stated they did not know what the impact would be, or were unsure what the question or protected characteristics meant. The second most prevalent theme was several respondents who stated that there would be no impact, or that they were not aware of any potential impacts.

While not addressing the impact of PAWHP directly, the next most common theme was some respondents stating that protected characteristics should have no impact on who receives PAWHP, i.e. the system should treat all eligible older people equally.

Some respondents, including Age Scotland and Inclusion Scotland, commented on specific protected characteristics. Most frequent were comments suggesting people with disabilities or health conditions, particularly those made worse by cold temperatures, could benefit from PAWHP, or should be given additional support to reflect their higher energy costs. The intersectionality between age and disability was also noted.

“The ALLIANCE agree with the conclusions of the equality impact assessment with regards to the protected characteristics of age and disability. As noted in the assessment, older people are more likely to be disabled and so there is some degree of interrelation between these two characteristics, and PAWHP by design is intended to have a positive impact on older people.” – The ALLIANCE

“Energy Action Scotland does not believe that the assessment presented in the consultation provides an objective or fair assessment of the impact on all protected characteristics… Whilst the provision of a payment is not considered to be negative the payment does no more for disabled pension age households than it does for non-disabled pension age households. This fails to recognise that other payments provided do not support disabled pension age households adequately with the increased power and heat demands of those with essential medical equipment and enhanced need to be warmer for longer hours at home.” – Energy Action Scotland

A few raised points about other protected characteristics. These included that ethnic minority women in Scotland may not be eligible because of pension rules, and that Asian British and Black British households are more likely to experience poverty in old age and therefore benefit from PAWHP. National Carer Organisations advocated for accessible resources to be produced to benefit ethnic minority groups, recommending the MECOPP briefing on Producing Accessible Information for BME Communities as a useful tool for this. One individual called for gypsy travellers to have all the information they need to access their entitlement, while National Carer Organisations raised concerns about the higher proportion of gypsy travellers who do not have a bank account and that the flat rates of PAWHP could entrench inequality due to the higher heating costs of this group. Two respondents noted that women might be positively impacted as they are more likely to have lower incomes and live alone in later life. South Lanarkshire Council noted that people with no recourse to public funds “will also be facing extreme fuel poverty and should not be excluded”.

Q18. Please set out any information you wish to share on the impact of PAWHP on businesses.

Around one in six respondents left an open comment at Q18. The most common theme was that there would not be an impact on businesses, with a few stating that as PAWHP was for individuals it should not affect businesses. Several respondents stated they were unsure, or unclear about the meaning of the question

Some individuals commented on potential impacts on energy companies. A few recognised that energy companies could benefit as PAWHP would help customers pay their bills promptly; otherwise, companies could lose out if they have to deal with non-payment. Conversely a few raised concerns that energy companies could benefit if the payment is made directly to them in the future, with potential for profiteering. A small number who held negative views about energy companies argued it was unnecessary to consider the impact on those businesses.

Potential impacts on care homes were mentioned by some, though varied comments were made. A few suggested care homes would benefit from the payment, especially if it is paid to them directly; others argued that care homes should not be able to benefit financially. One argued that removing the payment from people in residential care could negatively impact social care costs. Others made more general comments about the role of care homes which have been covered in Q9.

A few suggested that other businesses might benefit if older people had more money to spend on other things. One individual felt the NHS would benefit due to less demand on hospitals and GPs. Another noted that businesses which need to provide new or additional information could incur costs, but did not specify which businesses this referred to.

“If individuals who receive payments are physically and mentally healthy by being kept warm, they are likely to be more social and outgoing and this would impact on businesses.” – Individual

Q20. Please set out any information you wish to share on the impact of PAWHP on reducing inequality of outcome caused by socio-economic disadvantage.

One quarter of respondents left an open comment at Q20; however, as with the other impact assessment questions some stated that they were unclear about the question or did not know whether there would be any impact.

The most common theme was several respondents who stated there would be no impact on reducing inequality of outcome caused by socio-economic disadvantage. There were two strands to these comments. Some respondents argued there would be no or negligible impact from PAWHP or that reducing disadvantage was not the policy's aim. Some other respondents highlighted that there would be no further impact because of the like-for-like replacement of the existing benefit.

“It will do nothing to reduce the inequality of outcome caused by socio-economic disadvantage. The amounts which people are to receive is a drop in an ocean of inequality and disadvantage faced by lower socio-economic groups.” Individual

Conversely, the next most prevalent theme was that PAWHP could positively impact disadvantaged or low-income groups. However, some acknowledged that the impact on tackling poverty or fuel poverty could be small. Aligned with this theme, some others made general comments reiterating the need for PAWHP because older people are more likely to be in fuel poverty or have lower incomes than other population groups.

“Will be very beneficial as it will help to bring people a better standard of health and wellbeing when they can heat their home without fear of not affording the heating bill” – Individual

“Although PAWHP is a universal payment, it will provide the greatest benefit to households with lower incomes, and should be considered part of the Scottish Government’s wider attempts to reduce poverty, including fuel poverty.” – The ALLIANCE

“Many older people are on low, modest, or fixed incomes, and are more financially squeezed than ever before. 15% of pensioners in Scotland are living in poverty, with 10% living in absolute poverty. The PAWHP is vital in addressing this issue and helping the most disadvantaged older people through the winter months.” – Age Scotland

Some respondents highlighted the need for everyone to be treated equally, or for PAWHP to remain a universal benefit.

“Although targeted payments might seem like a good use of the devolved funding, we believe that many lower-income households containing disabled pensioners, women pensioners and BME pensioners who are not on Pension Credits would then miss out. As would those just over the Pension Credit line but who are nevertheless, because of high energy prices, still in fuel poverty. Therefore we continue to support this benefit being paid to all households containing older people unless they themselves choose to opt-out.” – Inclusion Scotland

Other themes, each raised by small numbers, included:

  • A view that PAWHP, as a universal benefit, unfairly supports people on higher incomes who do not need the payment.
  • General comments about the need to tackle poverty and inequality in Scotland.
  • Comments expressing frustration that older people who have worked and ‘contributed to society’ either do or could lose out on support, while other low-income groups continue to receive benefits.
  • Suggestions that energy companies should do more to alleviate fuel poverty.
  • Calls to extend the payment to disabled people to reduce their disadvantage.
  • Public Health Scotland noted that PAWHP may reinforce inequalities within the pension-age population.

“More disadvantaged groups have lower life expectancy, so they are less likely to receive the PAWHP for long periods of time or the higher rate paid to those aged 85+.” – Public Health Scotland



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