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.

4. Eligibility and value of payment

Chapter four presents the analysis of questions that asked respondents to consider the nature and clarity of the proposed eligibility criteria for PAWHP, the criteria for people in residential care who receive specific income-related benefits and the value of the payment.

Q6. Do you agree or disagree that our universal approach to identifying eligibility should be based on reaching state pension age? Please provide further information on why you agree or disagree.

n= Agree Disagree Unsure No answer
No. of all respondents 906 711 122 56 17
% of all respondents 906 78 13 6 2
% of all answering 889 80 14 6 -
% of individuals answering 873 80 14 6 -
% of organisations answering 16 81 19 0 -
  • Miscellaneous
5 100 0 0 -
  • Health / disability / age
7 86 14 0 -
  • Poverty / fuel poverty
1 0 100 0 -
  • Local Authority
3 67 33 0 -

Four fifths (80%) of all respondents and all individuals who answered Q6 agreed with the universal approach to eligibility, with 14% disagreeing and 6% unsure. Among organisations who answered, 81% agreed and 19% disagreed. Only one poverty/fuel poverty organisation answered, disagreeing with the approach.

Stage pension age is appropriate

Three fifths of respondents provided open comments. Most commonly, respondents agreed that the state pension age is an appropriate basis for eligibility because this is the age when people need additional support. Multiple reasons for this included:

  • This is when people typically stop working and face a drop in their income or move onto a fixed income. This can mean many older people, especially those who receive only state pension, are not well off and need financial support.
  • People at this age have paid taxes and contributed throughout their working lives.
  • Older people are more likely to be at home and will incur higher energy bills.
  • Older people are more likely to be vulnerable to cold weather and suffer poor health due to cold temperatures. Warmer homes are crucial to health and wellbeing and prevent injuries, trips and falls amongst older people, so ensuring people can afford energy bills will reduce pressure on health and social care services.
  • Working-age people are eligible for other benefits or can earn, so they do not need, or should not be entitled to, the payment.

“We strongly believe that warmer homes for the elderly will prevent unintentional injuries from slips, trips and falls within their homes.” - Scottish Community Safety Network

In addition, many respondents left brief comments expressing their general agreement with eligibility at state pension age or stating that the criteria seemed fair and sensible.

Many said eligibility should be based on state pension age because the current criteria work well and should be maintained on a like-for-like basis, or reiterated calls not to change the WFP system at all.

Agree with a universal approach

Agreement with maintaining a universal approach, regardless of personal circumstances, was expressed by many. Reasons given included that this is fairer, avoids discrimination, increases public support for the payment, promotes uptake, protects those on low and modest incomes, and meets everyone’s basic need to stay warm in winter and cope with increased financial costs.

Several argued against means testing PAWHP for similar reasons. These included that is unfair to those who made provision for their older age, is a stressful process for claimants, is costly and complex to administer, and can cause some people to miss out on a payment. Some specifically did not want eligibility to be based on receipt of pension credit only, expressing concern that many on low incomes are just above the cut off for this, meaning they miss out on vital support or end up worse off than those who receive pension credit. Others highlighted that pension credit is not taken up by many who are entitled to it. Age Scotland noted there can be negative impacts on individuals’ health and, in turn, NHS and social care services, due to lower uptake of non-universal benefits.

“Many miss out on social security benefits because they have a small private pension or small savings that put them over the threshold… even though people are sometimes only a few pounds over a limit and/or are still on low incomes, they... miss out on other support (like the Winter Heating Payment, energy efficiency grant funding, and Warm Home Discounts from their energy supplier).” – Age Scotland

“2.1 million (18%) of pensioners in the UK live in relative poverty with some groups such as 29% of Asian/Asian British pensioners; 25% of Black/Black British and 26% of single older women being in poverty… this lump sum payment is helpful in meeting the additional costs associated with higher fuel bills… without going through a means testing process which would reduce take-up. For example, if the payment was linked to receipt of Pension Credits, only 60% of those entitled to that benefit would receive it.” - Inclusion Scotland

It is a simple, efficient and cost-effective approach

Many respondents argued that eligibility based on state pension age is easy to understand, avoids complicated form-filling for clients, or is a cost-effective and efficient way to identify clients and administer the payment. Similarly, alternative criteria, such as means testing, were felt to be too confusing for clients, or too complex to administer. This could lead to people missing out on support, increased administration costs, or people trying to take advantage of the system.

“Using state pension age as the core criteria… is clear, consistent and simple… it eases delivery by maintaining a link with another universal payment that the DWP already collect the data necessary to deliver.” - The ALLIANCE

Extending eligibility

Situations where people under state pension age should qualify were outlined by many individuals and two organisations, including those who agreed and disagreed with the closed question. Most commonly, groups likely to need additional support with heating costs were identified, including: veterans, those with disabilities or health conditions, widowed people, those living off-grid or in rural or island areas, unemployed people, unpaid carers, and people living in poverty. It was highlighted that these groups are more likely to live on low incomes, be at home more, require warmer homes, or have higher energy costs.

“Disabled people need to have funds to heat their homes for longer as their needs are just as important as the elderly… My health is greatly affected if I can't afford to keep myself warm, I get depressed with everything I need to contend with on a daily basis and to add a cold house on top of this makes me dread winter.” - Individual

Several respondents also mentioned the rising state pension age. A few emphasised that the rising pension age had particularly disadvantaged women. There were calls to fix the PAWHP eligibility age to stop people from missing out on the payment in the future should the pension age rise again. A small number also called for the eligibility criteria to be extended to those below state pension age, e.g. aged 60 and over.

“The pension age keeps moving (higher); elderly people don’t stop being old and cold because the pension age rises. It should be like the bus pass; once you’re passed 60, you should get it.” – Individual

Arguments for better targeted eligibility criteria

Several individuals, including those who agreed and disagreed with the closed question, advocated for some form of means testing of PAWHP to be introduced instead of or in addition to age-based criteria. It was frequently argued that not all older people need financial support. Conversely, it was suggested that alternative or additional income-based eligibility criteria could be used to identify and target the payment to those who need it most. A small number felt that the payment should only be awarded to those of state pension age who were no longer working.

“As more and more people are remaining in employment the government’s costs could be shaved a bit by giving this benefit to individuals who are actually retired and not working.” -Individual

Less commonly mentioned themes

A few respondents each argued for eligibility criteria to ensure that only those who had worked and paid taxes should receive the payment, or that those who live abroad should not be eligible.

Q7. Do you agree or disagree that the eligibility criteria for the PAWHP are clear? Please provide further information on why you agree or disagree.

n= Agree Disagree Unsure No answer
No. of all respondents 906 544 125 217 20
% of all respondents 906 60 14 24 2
% of all answering 886 61 14 24 -
% of individuals answering 870 61 14 25 -
% of organisations answering 16 94 6 0 -
  • Miscellaneous
5 100 0 0 -
  • Health / disability / age
7 100 0 0 -
  • Poverty / fuel poverty
1 0 100 0 -
  • Local Authority
3 100 0 0 -

Three fifths (61%) of all individuals who answered agreed that the eligibility criteria for PAWHP are clear; 14% disagreed and 25% unsure. Among organisations who answered, 94% support was the joint highest level of agreement recorded by organisations across the consultation questions.

Clear criteria

Two fifths of respondents commented in Q7 and in line with the closed question results the most prevalent theme was that PAWHP eligibility criteria are clear, straightforward, or easy to understand. While some explained what they understood the criteria to be, many others gave reasons for why the criteria are clear. These included that: they only require people to know the state pension age; the payment is universal; the criteria are indicated in the name of the payment; or the criteria are the same as the existing WFP. A small number also mentioned that information in the media or communications about the WFP helped them understand the eligibility criteria.

“It is published in the news, and also you get a letter to tell you when you are eligible.” - Individual

Despite agreeing that the eligibility criteria are clear, several respondents reiterated their disagreement with the criteria or stressed that they are only easily understood if there are no future changes. A few emphasised that the current criteria will likely be clearer than those that apply under an alternative system such as means testing.

Unclear or need to be clearer

The second most common theme was that the eligibility criteria are unclear or need to be made clearer. Some respondents made brief comments to this effect, or felt the criteria were unclear due to the confusing nature of the benefits system or regular changes to the benefits criteria or state pension age.

Some others criticised the consultation paper's lack of clarity, detail and language. Respondents expressed a view that some of the information in the paper was unclear, lacked sufficient detail, or was deliberately misleading, in particular about the qualifying week or who will be eligible for PAWHP in the future.

“Not clear from guidance if proposal is to continue on same basis for future recipients, or if "same basis" approach only refers to current recipients.” - Individual

“Not sure what "and their circumstances during the qualifying week" means. No mention of what can change entitlement.” - Individual

Several respondents stated they were confused about the criteria. For example, they are unsure of the state pension age, the age at which PAWHP will be paid, or what the criteria mean for those who reach state pension age in 2024. Other comments suggested that respondents were unaware of or had misunderstood the criteria. These comments indicated that respondents: believed the current eligibility criteria used by the DWP might change; thought the payment would be for those receiving pension credit or income support only; assumed that they would begin to receive the payment at aged 65; or had not realised that those cohabiting would receive a smaller value payment.

Groups for whom the criteria might be more complicated were highlighted by some. These included those who live outside Scotland, retire before state pension age, or for whom the qualifying week will be relevant because of their birthday.

“The basic eligibility criteria of being of State Pension age should be widely understood (notwithstanding the confusion sometimes experienced by those who reach State Pension age after the qualifying week and therefore currently do not receive the payment, but still experience the Winter as a pensioner).” - Independent Age

“People who retire before state pension age could be confused by calling it a pension payment.” - Individual

Some called for more information about, or explanation of, the criteria or made suggestions for how to make the criteria more accessible. These included: providing more explanation about qualifying dates and rationale for these; running advertising campaigns; distributing information leaflets; creating audio-visual resources; and contacting people to let them know they are entitled to the payment. It was suggested that this could be particularly relevant for people with visual impairments or who do not have digital access or skills. However, one individual cautioned against providing too much information, which could be overwhelming.

“We have heard from older people that often understanding the value of what they or their household would receive can be confusing. It would be an opportunity in taking over the payment to create easy to understand, fully accessible guidance and awareness campaigns on the payments.” - Age Scotland

Criteria clear under the DWP system

Several individuals acknowledged the criteria are clear because they are the same as the WFP eligibility criteria. Some of these respondents, however, disagreed with the closed question element of Q7, arguing that because the existing criteria are clear there is no need to change, or expressing concern that devolving the payment to the Scottish Government could lead to unnecessary or confusing changes to the criteria.

Q8. Do you agree or disagree with the proposal to retaining the current value of payments? Please provide further information on why you agree or disagree.

n= Agree Disagree Unsure No answer
No. of all respondents 906 489 248 137 32
% of all respondents 906 54 27 15 4
% of all answering 874 56 28 16 -
% of individuals answering 860 56 28 16 -
% of organisations answering 14 50 36 14 -
  • Miscellaneous
5 60 40 0 -
  • Health / disability / age
6 50 17 33 -
  • Poverty / fuel poverty
0 - - - -
  • Local Authority
3 33 67 0 -

Varied views were expressed on the payment value. While 56% of individuals who answered agreed with retaining the current value, 28% disagreed and 16% were unsure. Half (50%) of organisations who answered agreed, the joint second lowest level of agreement among this group across all consultation questions; the remaining 36% disagreed and 14% were unsure.

Should be higher to reflect energy costs

While a majority of respondents agreed with retaining the current value at the closed question, the most common theme in responses to Q8 was that the payment should increase as the cost of fuel and energy increases. Most disagreed with the current value for this reason; however, a few respondents agreed with the current value but still called for future payments to match any changes in fuel costs.

“Energy bills will therefore now account for a larger proportion of household expenditure than previously, and so replicating existing values of payment that may have risen only with the general rate of inflation will mean households are receiving less support in real terms than previously… In principle, we would therefore argue that consideration should be given to increasing the value of the payments proportionate with inflation or with the increase in energy bills, whichever is higher. This would reduce levels of financial hardship and fuel poverty amongst pension aged households, whilst also ensuring the payment continues to fulfil its intended purpose to the greatest extent possible.” – The ALLIANCE

“We disagree with the proposal to retain the current value of payments and believe that payments should be increased in line with inflation and to reflect the dramatic increase in energy bills over the past few years.” - National Carer Organisations

Should be higher or rise in line with inflation

The second most common theme, mentioned by many, was opposition to retaining the current value because it was felt it should increase with inflation or the cost of living. Again, a few respondents agreed with the current rate, but suggested it rise in future years.

“With inflation and war and other uncertainty in our world, I believe this payment should be more flexible and the ceiling raised to more than it is as and when necessary. Your figures fall short of what is currently happening, so I am confused and concerned.” – Individual

“Agree that they should be retained on transfer but uprated annually in line with wage or price inflation - whichever is the higher.” – Inclusion Scotland

Retain the current value

In contrast, many respondents agreed with retaining the current value of the payments. Most did not explain why they agreed, but those who did described the current value as fair, sufficient, and helpful. Some stated that the current payment is sufficient, but they would not want it to be any less. Many, including Age Scotland, suggested that while they were content with the current payment, they hoped there would be a policy in place to set a review for the future.

“The current payments are generous, and I do not think there is any argument for changing them.” – Individual

“Agree, however, a watchful eye needs to be on the cost of electricity, gas and heating oil and any adjustments made to ensure the benefit keeps the same value to the recipient.” – Individual

“I think you should do that for the first year, but you should decide NOW how the benefit will be raised annually to maintain its impact.” – Individual

Some agreed with the current payment as they believed increases would put further pressure on an already strained benefits system or the Scottish Government budget.

Less commonly mentioned themes

Other points each mentioned by a few respondents, from most to least prevalent, included the following. While these were typically reasons for disagreeing with the proposal, they were occasionally cited as caveats to agreement.

  • A general view that those in receipt of state pensions deserve more money.
  • Pensioners in Scotland should receive a higher payment due to experiencing colder weather and less well-insulated homes.
  • Disagreement that there should be a higher rate for those aged 80 or over.
  • Concerns that pensioners who live alone may be worse off than a household with two eligible adults, despite using similar amounts of energy to heat their home.
  • For PAWHP to be at the same level as any comparable payments made to people elsewhere in the UK.
  • People living in rural areas deserve a higher value payment.

Q9a. Do you agree or disagree that people in residential care who do not receive the income-related benefits listed should receive half of the ‘full’ rate of PAWHP?

n= Agree Disagree Unsure No answer
No. of all respondents 906 325 272 281 28
% of all respondents 906 36 30 31 3
% of all answering 878 37 31 32 -
% of individuals answering 865 37 31 32 -
% of organisations answering 13 62 8 31 -
  • Miscellaneous
4 50 0 50 -
  • Health / disability / age
6 50 17 33 -
  • Poverty / fuel poverty
0 - - - -
  • Local Authority
3 100 0 0 -

One third (37%) of all respondents and individuals who answered agreed with this proposal, the lowest level of agreement recorded both overall and by individuals across the consultation questions. Three in ten (31%) disagreed and a further three in ten (32%) were unsure. Three fifths (62%) of organisations that answered agreed, 8% disagreed and 31% were unsure.

It should be noted, however, that the qualitative analysis below suggests respondents disagreed for different reasons; they either felt a higher or full rate of payment was appropriate, or called for a lower or no payment to be made. There is evidence of respondents contradicting themselves within their responses. For example, some respondents agreed at both Q9a and Q9b, i.e. they agreed with a lower rate for those in residential care, but then used their open comment to call for everyone to be treated equally.

Question 9b. Do you agree or disagree that people in residential care who receive one of the income-related benefits listed should not receive PAWHP?

n= Agree Disagree Unsure No answer
No. of all respondents 906 367 215 291 33
% of all respondents 906 41 24 32 4
% of all answering 873 42 25 33 -
% of individuals answering 859 42 25 33 -
% of organisations answering 14 50 21 29 -
  • Miscellaneous
5 40 20 40 -
  • Health / disability / age
6 50 17 33 -
  • Poverty / fuel poverty
0 - - - -
  • Local Authority
3 67 33 0 -

While there was slightly higher agreement among those who answered that people in residential care who receive one of the income-related benefits listed should not receive PAWHP, overall only 42% agreed, with one quarter (25%) disagreeing and one third (33%) unsure. Agreement was slightly higher among organisations who answered with half (50%) agreeing. This was the joint second lowest level of agreement recorded by organisations across the consultation questions.

Q9c. Please provide further information on why you agree or disagree.

Open comments were provided by two fifths of respondents at Q9c. However, because Q9c covered both closed questions, it was often unclear which question respondents were referring to in their comments. Many also did not specify if they were referring solely to people in residential care who receive income-related benefits, or to all people in residential care. Where it was possible to make a distinction, this has been noted below. The analysis should also be interpreted with caution given that some respondents appeared to contradict themselves across Q9, as noted above.

Several respondents stated they were unsure or could not give an opinion about the PAWHP for those in residential care. Reasons given included the complexity of the arguments or because they did not have enough information about residential care payment systems, individuals’ circumstances and how residential care placements are funded, or whether PAWHP would be paid directly to residents or care homes.

PAWHP is not needed in residential care

While there was not a majority view in Q9c and Q9b, the most prevalent theme was that people in residential care should not receive PAWHP as heating is already covered in their care costs. Respondents argued that: care homes, not residents, are responsible for energy bills; the price of care should include heating; support is not needed as residents are already warm or do not face increased fees during the winter; and funding should be targeted to people in their own homes.

“Support should be targeted at those who are most in need. People in residential care are not at risk of disconnection and do not shoulder the same financial burden as those remaining in their own homes.”- Citizens Advice Bureau

Similarly, several respondents agreed that care home residents should not receive PAWHP if they already claim other income-related benefits. Some emphasised this was unnecessary for this group, on the assumption that if they were claiming income-related benefits, then their care costs were also likely to be paid by public funding. Others expressed concerns about a lack of fairness, arguing, for instance, that this group are already getting sufficient support or are already better supported than those who have to self-fund their residential care.

“For those in residential care and receiving relevant income-related benefits, as they would generally not be contributing to the costs of residential care, it is reasonable to exclude them from the payment entirely as they will not have even indirect responsibility for paying for energy.” – The ALLIANCE

However, Inclusion Scotland and one individual argued it would be illogical or unreasonable for those receiving income-related benefits, who are presumably less affluent, to be awarded less than those who do not receive benefits.

Should receive PAWHP to help cover care costs

The need for help to cover care costs was referred to by several to justify why those in residential care should receive some of or the full rate of PAWHP. Some highlighted the very high costs of care, that residents pay for their heating through their care fees, or that rising energy bills are passed onto residents through higher care fees.

“Residential fees are extortionate; people have to heat their rooms, and they should receive the same as anyone else. Some people have to sell their house to pay the fees.” – Individual

Several others highlighted the negative impacts on care service providers of rising energy costs, including struggling to remain open. They called for PAWHP to be paid directly to providers to cover rising energy bills and keep costs down for residents. Two individuals, however, expressed concern about residents being denied agency if they were not paid PAWHP directly. Some other respondents warned against profiteering by, or government subsidy of, care home businesses. There were comments that care homes may put their fees up or take recipients’ PAWHP without any additional benefit to residents.

Depends on individual circumstances

Many respondents felt that receipt of PAWHP, or the amount awarded, should depend on individual circumstances. Several suggested it should depend on how the costs of residential care are being met, in particular, advocating that those self-funding their care should receive the full payment. Respondents expressed a view that self-funding residents subsidise the cost of local authority places or pay a disproportionate amount more for their care. It was also suggested that halving the payment for those in residential care who do not receive income-related benefits would penalise those who had worked all their lives or saved for the future and now had to pay for their care. Age Scotland also cautioned that some residents who receive income-related benefits may still be self-funding part of their care and urged that this group also receive the full rate of PAWHP.

“Those living within residential care are often spending all of their pension or other savings to pay for this care… With the mix of local authority funded and privately funded places in residential care, those paying privately are often paying a disproportionate amount more, with recent research suggesting they pay, on average, 40% more than those publicly funded. With a third of all residents in residential care self-funding, this a significant proportion of older people paying more towards heating than others in the same setting, even though they are more often than not on the same income.” – Age Scotland

Some felt that only residents required to contribute towards energy costs in their establishment should receive any PAWHP. A few others argued that those on short-stay residential places or who will return to their own homes should still receive the payment.

A universal approach

The importance of keeping the benefit universal, regardless of people’s circumstances, was highlighted by several. They advocated for the payment to be made based on age, not circumstances, and called for the full payment to be made to all.

Helps support other heating and living costs

Some expressed support for care home residents receiving PAWHP, arguing they would still benefit from heating support, or highlighted other costs linked to the winter months. These included the need to: buy warm clothing or heated blankets; heat their rooms or their unoccupied houses to ensure they do not fall into disrepair; help their spouse at home; or buy Christmas presents and cards. A small number emphasised residents may need the payment to contribute to essentials or general living costs.

“People in care still have to pay for warm clothing and other items to keep warm” - Individual

Comments on shared residencies

A small number expressed mixed views about whether people in shared residencies should be paid a lower rate of PAWHP, or a rate in line with people co-habiting at home. These respondents felt individual heating costs would be reduced by pooling resources and splitting the bill with other residents, justifying a lower rate. However, Age Scotland disagreed that proportional sharing reduced costs, arguing that overall heating bills in residential care are higher due to larger building sizes and the need for warmer temperatures to care for people with health conditions, for example.



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