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.

6. Qualifying week

The Qualifying week is currently in September, and people who meet the eligibility criteria during the qualifying week are then paid automatically in November or December. This process allows the DWP to provide Social Security Scotland with data about eligibility in enough time for payments to be processed in advance of winter.

Q13a. Do you agree or disagree with the proposal to continue having the ‘qualifying week’ in September to identify eligible clients?

Q13b. Please provide further information on why you agree or disagree.

Q13c. If you disagreed, please provide a preference for when you think the qualifying week for PAWHP should be.

n= Agree Disagree Unsure No answer
No. of all respondents 906 629 124 136 17
% of all respondents 906 69 14 15 2
% of all answering 889 71 14 15 -
% of individuals answering 872 71 14 16 -
% of organisations answering 17 82 18 0 -
  • Miscellaneous
5 100 0 0 -
  • Health / disability / age
7 71 29 0 -
  • Poverty / fuel poverty
2 100 0 0 -
  • Local Authority
3 67 33 0 -

Respondents who answered Q13 were supportive of continuing to have the qualifying week in September; 71% overall, 71% of individuals and 82% of organisations agreed with this approach.

Just under two fifths of respondents provided an answer to Q13b, and just under one in six answered Q13c. However, as respondents frequently suggested when qualifying week should be at Q13b, or gave reasons for their agreement or disagreement at Q13c, we have presented the themes evident at both questions below.

Agreement with the proposed qualifying week

By far the most prevalent theme in responses to Q13b was agreement with the proposed qualifying week in September. Respondents highlighted that because this is the same process as the WFP, it would be easy for clients to understand, simple to administer and cost-effective. Some specifically noted that it would allow enough time for payments to reach clients before winter.

“Earlier would mean less people qualify, later would result in more payments being paid in January and later causing worry for people concerned about affordability of heating bills. Historically people expect payment before Christmas and will make contact if this expectation is not met.’ – Individual

Those who reach state pension age after qualifying week miss out

Many respondents disagreed with the qualifying week in September, for varied reasons. Some disagreed because of the timing; this is addressed below. Most frequently, however, several highlighted that the process means that people with birthdays after September would not be eligible for the payment that year, regardless of the fact that they would be of state pension age during the winter.

The most prevalent theme at Q13c, mentioned by some, was that there should be no qualifying week and that eligibility should be assessed throughout the year. This would mean that eligibility is based on a person’s birthday or the year that they reach state pension age, rather than also factoring in the time of year. One individual called for pro-rata payments to be made over winter depending on when people reach pension age.

“The September cut-off date negatively impacts many people who have to wait another full year for payment. It's difficult enough for those also impacted by the rise in state pension age and having to wait 6 or 7 years longer to get such without a large number also being forced to wait even longer for winter fuel payment.” - Individual

Necessity of a qualifying week

Several respondents acknowledged that a qualifying week was necessary. Some agreed that September was a suitable time, while others were unsure of the best timing.

“Obviously a lot of people will 'miss out', but I do understand the need to get all the admin prepared for those eligible for payments and as I have no current alternative, I remain 'unsure', but not against it.” - Individual

A few organisations partially agreed, again acknowledging the need for a qualifying week, but suggesting changes to the timing would improve the service, as noted below.

Alternative timeframes

While some respondents at Q13c reiterated their disagreement with the qualifying week without providing alternative suggestions, several highlighted specific changes to the timing of the qualifying week. Beyond assessing eligibility throughout the year, other suggestions from most to least prevalent included:

  • Pushing the qualifying week back to December to include people who reach pension age in the calendar year. Others recommended January or the first of January specifically for the same reason.
  • Bringing forward qualifying week to summer, as September can feel cold for some.
  • October was suggested, though respondents did not provide further detail.
  • Spring was mentioned as it is the start of the tax year.

RNIB agreed with a qualifying week but recommended moving it closer to the payment date to close the gap between those who reach pension age after the current qualifying week and before payment. The ALLIANCE advocated that the qualifying week be the same as the qualifying week for Child Winter Heating Payment to “ensure consistency of approach across payments”.

Other reasons for disagreeing with the timing of the qualifying week, rather than the process per se, included suggestions for a longer qualifying period. For example, South Lanarkshire Council proposed a September-long period “is more appropriate to cover those of mixed age in receipt of Universal Credit”. Inclusion Scotland suggested a qualifying week be as late as possible, which in their view should be feasible given that most of the administration is now online.

Other considerations

Some comments combined consideration of the qualifying week with the wider eligibility criteria. There were calls for greater flexibility to allow consideration of people who may be on holiday during the qualifying week and those who are temporarily in care homes. A small number of respondents noted that they believed those who live abroad for most of the year should no longer be eligible to receive the payment, regardless of their status during the qualifying week.

Child Poverty Action Group and Independent Age agreed with the proposal, but suggested clients would benefit if there were a mechanism for payment for those who reach state pension age after the qualifying week but before the end of the application window. Age Scotland recommended an application process for those clients who may not have been identified automatically, e.g. if they recently moved to Scotland.



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