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.

Other consequences or considerations

Q16. Can you identify any potential unintended consequences which we have not considered in these proposals?

The most common theme raised by the two fifths of respondents who answered Q16 was that there should be no unintended consequences arising from the proposals. Many simply stated there would be none, but some elaborated that the like-for-like nature of the replacement meant there should be no impact.

The next most prevalent theme was that some felt a greater cost would be associated with administering a devolved payment. It was suggested that costs would include new systems and administration and the payment itself, which could be detrimental to Scotland’s budget and lead to higher taxation or more government debt. A few individuals called for the budget for PAWHP to be ring-fenced for the payments.

A concern that people could lose money or poverty could increase was expressed by some. Respondents envisaged future changes being made to the payment or means testing being introduced, resulting in smaller or no payments to those on Pension Credit or with a private pension. A few expressed a concern that older people in Scotland could receive less than in other parts of the UK, or that people could lose out if data is not transferred from DWP promptly, or if data used to determine eligibility is out of date.

Some respondents highlighted that replacing the payment, in particular changing its name, could lead to confusion, stress and anxiety. This could apply to older people generally, but especially to those with disabilities or mental health conditions. Respondents suggested ensuring the change is clearly communicated, or clients could end up wondering where their previous payment has gone, or thinking they are getting both the old and new payment. More specifically, two individuals argued that extending re-determination to 56 days could cause unnecessary worry or hardship, and Energy Action Scotland noted that more clarity is needed about the timescales of the First-tier tribunal if Social Security Scotland has not reconsidered a redetermination after 56 days.

“At present, the UK DWP letters are headed "Your 2023 Winter Fuel Payment will be £500". In the middle of the letter it points out that this includes the "Pensioner Cost of Living Payment". Most people won't really notice that, hence a new Scottish winter heating payment will look like we are being "cheated" out of something. How are you going to explain this in very simple terms?” - Individual

Other potential unintended consequences mentioned included:

  • Other vulnerable groups could be at risk if the eligibility continues to be people over the state pension age. Some respondents referred to disabled people as well as those with health conditions, mental health conditions and homeless people.
  • An increase in ill health and deaths if some cannot afford their energy bills, putting additional pressure on the NHS.
  • The need to consider whether any changes to the eligibility or value of PAWHP negatively impact the receipt of other benefits or payments.
  • The cash payment being used for other purposes, particularly at Christmas.
  • Considering how the payment can be made to those without a bank account.
  • One individual each argued that the payment could act as a disincentive to people making their homes more energy efficient, or to energy companies reducing prices.

Q21. If there is anything else you would like to tell us about the described policy intention, impact assessments or PAWHP in general, please do so here.

One fifth of respondents left a comment at Q21. Most comments reiterated points related to specific consultation questions covered elsewhere in this report. Most common was a call for no changes to the WFP, concerns about the Scottish Government’s ability to manage PAWHP, and various comments about eligibility.

Other points each raised by a small number of respondents included:

  • Calls to ensure that the transfer of the benefit goes smoothly and that there are no interruptions to the payment being made.
  • Requests from Public Health Scotland and a few individuals to monitor and review the impact of any changes on an ongoing basis.
  • Calls for more information; though a few requested details available in the consultation paper, others noted that the consultation required people to access online links and could disenfranchise older people without digital access.

“Cannot think of any unintended consequences arising from these proposals. A good monitoring policy put in place at the start to deal with any unintended consequences that become apparent in future would be recommended so that any issues could be dealt with in a timely fashion.” - Individual



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