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.

2. Overall views on PAWHP

The first questions in the consultation paper focused on overall views about the transfer of the Winter Fuel Payment (WFP), on a like-for-like basis, from Westminster to the Scottish Government. Respondents were asked if the payment is an effective way for the Scottish Government to provide financial support for older people, and to comment on the proposed name of Pension Age Winter Heating Payment.

Q1a. Do you agree or disagree with the proposal to replace Winter Fuel Payment with a ‘like-for-like’ replacement? Please provide further information on why you agree or disagree.

n= Agree Disagree Unsure No answer
No. of all respondents 906 489 251 156 10
% of all respondents 906 54 28 17 1
% of all answering 896 55 28 17 -
% of individuals answering 877 54 28 18 -
% of organisations answering 19 79 21 0 -
  • Miscellaneous
5 80 20 0 -
  • Health / disability / age
8 100 0 0 -
  • Poverty / fuel poverty
3 33 67 0 -
  • Local Authority
3 67 33 0 -

Over half of respondents who answered Q1a (55%) agreed with the proposal for a like-for-like replacement; 28% disagreed, and 17% were unsure. Four fifths (79%) of organisations that answered supported the proposal. While all health/disability/age organisations that answered were in favour, only one of the three poverty/fuel poverty organisations that answered supported the proposal.

Three quarters of respondents provided qualitative comments in Q1; the highest level of response to any of the consultation’s open questions. Many respondents used the first question to comment on issues which were the focus of other later questions. To avoid repetition, these comments have been included in the analysis of the most relevant question, which is noted below.

Agree with a like-for-like replacement

The most prevalent theme in responses to Q1 was agreement with a like-for-like replacement. These respondents, almost all of whom agreed with the closed question and a few who were unsure, supported the transfer on the basis that it will be truly a like-for-like replacement, i.e. everything stays the same as the WFP and no one loses out as a result. Many respondents commented that the WFP currently works well and agreed with using the same approach.

Organisations who agreed with a like-for-like replacement included Inclusion Scotland, Independent Age, Age Scotland, Health and Social Care Alliance Scotland (The ALLIANCE), Public Health Scotland, Citizens Advice Bureau, Energy Saving Trust, National Carer Organisations, South Lanarkshire Council and Shetland Islands Council.

“It’s a status quo situation. I like the present set up and so like the replacement.” – Individual

“I agree so long as no pensioner in Scotland would be disadvantaged by the change from the current DWP Payment to the proposed Scottish Government payment.” – Individual

“As the current Winter Fuel Payment takes a universal approach, in principle we agree with introducing the Pension Age Winter Heating Payment on a like-for-like basis. Unlike other social security payments that have been devolved to the Scottish Parliament, there is no need to revisit often restrictive eligibility criteria, either in the short or long term.” – The ALLIANCE

Some other individuals who agreed at the closed question did so on the basis that PAWHP continues to be a universal benefit paid to all people over state pension age.

General comments in agreement were left by some individuals, describing a like-for-like replacement as a sensible and fair approach.

Disagree because the current system works well

The second most prevalent theme in Q1 was respondents who disagreed or were unsure because of the effectiveness of the current WFP. Many respondents left short comments stating that the current system works well and should not be changed, particularly if the replacement is intended to be the same.

“It works fine as it is, so why mess with it.” – Individual

“If it is like-for-like, why is it being done?” – Individual

“I cannot see why you are trying to fix a system that is not broken.” – Individual

Many others provided more detail, elaborating that creating a like-for-like replacement for a working system is an unnecessary waste of time and money. Several argued strongly that the current process should be left alone and repeated this view at multiple questions. Others argued that it was going to cost a lot of money when the only change they could see was to the name of the payment..

“If it costs a lot of money to administer and we are all going to get the same then what is the point of changing?” – Individual

Financial support helps older people

The next most prevalent theme was general comments highlighting the importance of a payment to help older people to heat their homes. Most respondents agreed with a like-for-like replacement at the closed question, though their comments focused more on the need for a payment rather than the nature of the proposed payment.

“Continuation of funds to allow older people to help to afford to heat their home” – Individual

“It certainly is a big help in allowing particularly elderly and infirm to use extra heat.” – Individual

“This payment is an important part of the social security package for older people in Scotland. It provides a valuable cash boost moving into the colder months, and critically, the universality of the payment ensures that the vast majority of Scotland’s older adults – including those who are the most vulnerable and least financially secure – also benefit. This is in the context of 150,000 Scottish pensioners living in poverty, and an estimated 34% of those entitled to Pension Credit failing to claim support worth at least £332 million every year.” – Age Scotland

Scottish Government management of PAWHP

Many individuals raised concerns about the competence or trustworthiness of the Scottish Government or the SNP to manage the payment; this was also the second most prevalent theme in responses to Q2. It should be noted that this theme was evident across multiple consultation questions, but has been noted here to avoid repetition.

Views included a lack of confidence that the budget for, or administration of, the payment would be handled effectively and concern that the payment would be reduced in future (see below). Several respondents noted their perceptions of the Scottish Government’s poor management of public services and not keeping commitments, expressing a worry that this would also be the case with PAWHP. Some expressed the view that the change was only being proposed to differentiate Scotland from the rest of the UK. A few disliked the changes the Scottish Government had made when transferring the Cold Weather Payment to the Winter Heating Payment.

“The scheme seems to work; if the Scottish Government changes the way it runs at present, they will turn it into a disaster.” – Individual

Conversely, several respondents in Q1 and some in Q2 argued it was better for the Scottish Government and Social Security Scotland to manage the benefit. It was felt that their approach to social security was preferable to Westminster’s, that Scotland should run its own affairs, or that devolving the benefit offered flexibility to make changes later.

“I am currently in receipt of this payment. As a general rule, I think as many functions as possible should be transferred to Scottish governance/oversight. A like-for-like replacement seems fairest; I assume you would have the ability to adapt it in future if desired.” – Individual

Uncertainty about whether it will be a like-for-like replacement

Several respondents, including some who disagreed or were unsure at the closed question and a few who agreed, questioned whether the replacement would be truly like-for-like. Concern was expressed that changes could be introduced in the future, such as means testing or only providing the payment to those on Pension Credit, a lower value payment, or a different approach for people who are yet to reach state pension age.

“I don't believe that this will be like-for-like; as time goes on the goalposts are sure to be moved so that a lot of people who are just above a threshold will no longer qualify.” - Individual

More effective targeting

Some respondents, most of whom disagreed or were unsure in Q1, argued the payment should be better targeted. Individuals often focussed their comments on suggesting that means testing would ensure the payment goes to households that need it most rather than those who are more financially secure. A few organisations, including Energy Action Scotland, the Poverty and Inequality Commission, The Scottish Fuel Poverty Advisory Panel, and RNIB Scotland, called more broadly for the Scottish Government to use the benefit transfer as an opportunity to target the payment to tackle fuel poverty more effectively. This is covered more in Chapter 9.

“This payment should be targeted at those most vulnerable - for example, with a low income or disability benefit in place. This payment is for all people of State Pension Age and there will be a proportion of recipients who do not require this assistance. Given financial pressures currently it may be useful to apply a 'test' to this payment.” – Stirling Council

“The transfer of the WFP to Scotland provides an opportunity to use existing funding in a more efficient, targeted, and outcomes-focused way. The Panel believe that the Scottish Government would be remiss to pass up on this opportunity.” - The Scottish Fuel Poverty Advisory Panel

Other themes

There were calls for more information from some respondents who wanted to know more about the changes or what like-for-like means in practice before being able to comment.

A range of other points were raised in Q1 by individuals and organisations that are addressed later in this report. Some commented on the value of the payment (see Chapter 4), the needs of remote rural, island and off-gas grid households (see Chapter 8), and some shared views on the qualifying week (see Chapter 6). A few commented on the name of the payment (see Q3 below) and on the eligibility criteria, including extending eligibility (see Chapters 4 and 9).

Q2. Do you agree or disagree that this approach is an effective way for the Scottish Government to provide financial support for older people? Please provide further information on why you agree or disagree.

n= Agree Disagree Unsure No answer
No. of all respondents 906 523 225 146 12
% of all respondents 906 58 25 16 1
% of all answering 894 59 25 16 -
% of individuals answering 876 58 25 17 -
% of organisations answering 18 89 11 0 -
  • Miscellaneous
5 100 0 0 -
  • Health / disability / age
8 88 13 0 -
  • Poverty / fuel poverty
2 50 50 0 -
  • Local Authority
3 100 0 0 -

Almost three fifths (59%) of those who answered agreed that the proposed approach is effective, while one quarter (25%) disagreed, and 16% were unsure. Very high levels of support were recorded among organisations who answered, with 89% agreeing.

Two thirds of respondents answered the qualitative element of Q2. However, many did not directly answer the question, with the most prevalent theme being calls to keep the existing WFP and not make any changes, as outlined in Q1. While various other comments were made, many aligned with the focus of other consultation questions and have been addressed elsewhere in this report.

Positive impact on older people

Many respondents felt the proposed approach effectively addressed fuel poverty among older people. Many reiterated the difficulties older people face paying energy bills and emphasised the necessity of the benefit, with a few organisations stressing that even greater support was necessary. RNIB Scotland noted that their recent survey had identified that 62% of older people had cut back on heating to make ends meet. Age Scotland reported that their research estimated that 43% of people over 50 live in fuel poverty, and their 2023 National Housing Survey indicated that rates of fuel poverty amongst those of pensionable age had doubled to 39% since 2021.

“Additionally, in our most recent Big Survey in 2023, 41% of respondents felt financially squeezed, with a further 35% feeling they would be within the next year. Most of these respondents (68%) already received support in the form of energy bill support and 43% also received the Pensioner Cost of Living Payment, yet still felt financially squeezed and worried about bills. This highlights the importance of this payment remaining universal, and perhaps the need for additional or increased financial support, particularly for older people on state pensions and for those living in the coldest areas and/or who have higher energy needs (such as health conditions or medical equipment).” – Age Scotland

“It is effective because heating costs rise at this time of year, so an additional payment is very helpful, particularly for those who have limited income.” - Individual

Some individuals felt the approach effectively helped older people stay warm as it enabled confidence in using heating, knowing that bills could be paid. It was noted that older people are more likely to stay indoors during winter, so heating was needed. Some felt the payment would effectively address health issues caused by low temperatures.

“Older people are more vulnerable than other adults to cold without realising that they have become cold. If payments were to cease or reduce, older people would be more careful with heating bills and are more likely to stress their bodies and die prematurely as a result.” – Individual

General agreement

Several individuals provided brief comments agreeing with the proposal for PAWHP, describing it as fair, helpful, smooth, efficient and sensible.

Suggestions for distributing the payment

Ways to allocate the funding, such as directly to older people, or comments on administering the benefit, were made by several. A few organisations referenced the 96% uptake of the existing WFP, and it was felt that automatic payments were more efficient than means testing, which could require application processing and work to encourage take-up. However, some, including Energy Action Scotland, argued that a universal payment is not the most effective way to target support; this is addressed more in Chapters 4 and 9.

“As reflected in the consultation paper, the universal entitlement to and automatic payment of the existing Winter Fuel Payment has led to an extremely high take-up rate. This suggests current delivery mechanisms are highly effective and should continue to be so after the introduction of the new payment. Where appropriate, as in this case, universal payments are generally an effective means of delivering support to a target group. Reducing the need to understand and assess entitlement against often complex eligibility criteria ensures that as many people as possible can access the payment, whilst minimising the administrative resource necessary for delivery.” – The ALLIANCE

Other themes

Some respondents appeared to suggest they thought PAWHP would be means tested or only available to people receiving Pension Credit, or requested more information or reassurance that this would not be the case. A small number felt the payment could help address poor housing conditions.

Q3. Do you agree or disagree with the proposal to name the replacement for Winter Fuel Payment in Scotland ‘Pension Age Winter Heating Payment’ (PAWHP)? Please provide further information on why you agree or disagree.

n= Agree Disagree Unsure No answer
No. of all respondents 906 386 357 141 22
% of all respondents 906 43 39 16 2
% of all answering 884 44 40 16 -
% of individuals answering 867 43 41 16 -
% of organisations answering 17 76 24 0 -
  • Miscellaneous
5 60 40 0 -
  • Health / disability / age
7 86 14 0 -
  • Poverty / fuel poverty
2 100 0 0 -
  • Local Authority
3 67 33 0 -

Views on the proposed name for the payment were mixed among those who answered Q3. Overall, 44% agreed with Pension Age Winter Heating Payment, 40% disagreed, and 16% were unsure. There was, however, higher support among organisations who answered (76%).

The new name is clear and accurate

Two thirds of respondents left an open comment in Q3. The most prevalent theme was that the proposed name was clear and accurate. Many respondents, including Citizens Advice Bureau, RNIB Scotland, The ALLIANCE, Age Scotland, Independent Age and Energy Action Scotland, stated they felt the name was clear, straightforward, easily understood, and accurately described the benefit and the target audience.

“We agree with the suggestion to change the name of this benefit, which aligns with Scottish Government benefits and clearly states criteria within the name.” – Age Scotland

“Energy Action Scotland agrees that the renaming of the payment makes it clear who is eligible for the payment and its general purpose to support the need to heat homes during the coldest part of the year.” – Energy Action Scotland

The name does not matter

Many individuals left brief comments suggesting the benefit's name was irrelevant. Instead, it was argued that maintaining a universal benefit or delivering an effective support system is more important for the intended audience.

The new name is too long or confusing

South Lanarkshire Council and many individuals felt the name was too long or convoluted, expressing a preference for the existing name. Comments included that it was too clumsy, a mouthful, unwieldy and should be shorter to be memorable.

Many individuals disagreed with changing the name of the payment, arguing that people were already familiar with WFP. While most organisations agreed with the proposed name, one disagreed because of the potential for confusion, and a few others stressed the need to communicate the change clearly to avoid any confusion.

“Social Security Scotland should communicate the change in name and why this has changed, reassuring older people that they have not lost eligibility to the Winter Fuel Payment.” – Independent Age

Remove reference to ‘Pension Age’

Some individuals suggested removing Pension Age. Comments included that highlighting age could be discriminatory, could attract negative attitudes from those not of pensionable age who are not receiving support, or did not reflect ineligibility amongst those retiring earlier than the state pension age. National Carer Organisations disagreed with the name, noting that including Pension Age could limit changes to the benefits they called for.

“We disagree with the proposal to name the replacement payment ‘Pension Age Winter Heating Payment’. We would argue that the payment should be extended to include unpaid carers of any age who struggle to pay their heating bills. The current recommendation for the name, therefore, does not factor in for future improvements to the payment to include unpaid carers.” – National Carer Organisations

Include reference to Scotland

It was suggested by some individuals that the word Scotland or Scottish could be included. Most commonly, using the existing title with Scotland added was preferred, though the Scottish Winter Heating Payment was also suggested.



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