Pension Age Winter Heating Payment (PAWHP): equality impact assessment

Key Findings

Protected Characteristics

Age

32. Age is a protected characteristic under the Equality Act 2010. The policy to introduce universal PAWHP is exclusively designed to provide additional support to people of pension age in Scotland to help towards meeting heating costs during the winter. Therefore, this impact assessment will examine the impact of how the policy will affect this particular age group. Poverty and income inequality statistics define pensioners as adults who have reached their state pension age, with the state pension age for both men and women increasing to 66 years in the most recent reporting period of the Poverty and Income Inequality in Scotland 2021-24 statistics.^[19]

33. According to a 2023 report by Independent Age, pensioner poverty is a growing issue in Scotland, with one in seven people over state pension age living in poverty in Scotland. ^[20]

34. Similarly, the Scottish Government estimates that 15% of pensioners (150,000) were living in relative poverty after housing costs in 2020-23.^[21] Before housing costs, 17% of pensioners (170,000) were in relative poverty. Pensioner poverty rates are typically higher before housing costs than rates after housing costs, because the majority of pensioners tend to have a relatively low income but incur low housing costs as they own their home. It is therefore more meaningful to use the after-housing-costs poverty measure for comparing the standard of living between pensioners and other age groups.

35. The 2023 SHCS includes the 2023 criteria for WFP prior to the introduction of restricted eligibility, and estimates that 861,000 households were in fuel poverty in 2023. This rises by around 10,000 to 871,000 when the current, means-tested PAWHP approach is applied to the 2023 data. When applying the proposed approach of universal eligibility to the 2023 SHCS data, we would estimate around 865,000 households to be in fuel poverty. The universal approach would therefore reduce the number of households in fuel poverty under the current criteria by 5,000, when compared to 2023 levels using the means-tested PAWHP criteria.

36. The 2023 SHCS found that families (34%) have similar rates of fuel poverty to older households (37%), and other households (32%). However, other households have lower rates of fuel poverty than older households. When considering extreme fuel poverty, families have a lower rate of extreme fuel poverty (12%) than both older households (25%) and other households (19%).

37. According to the 2023 SHCS, 491,000 households are in extreme fuel poverty under the original WFP eligibility, prior to the introduction of means-testing. This is expected to have increased to around 501,000 households under the means-tested PAWHP. Conversely, we would estimate a decrease to 495,000 households under the proposed, universal PAWHP eligibility. Therefore, the introduction of a universal PAWHP would move around 6,000 households out of extreme fuel poverty compared to the current PAWHP criteria.

38. Older people are also more likely to live in less energy efficient homes. The recent SHCS shows that older households (66.1) have lower average Energy Efficiency Rating than families (69.3) and other (adults without children) households (68.3). Poor energy efficiency is a key driver of fuel poverty.

39. Research published by Age Scotland in 2022 suggests that 76% of older people are always concerned about paying fuel bills. According to Age Scotland, just 16% of respondents to their 2022 ‘Taking the Temperature’ survey were very satisfied that they could heat their home to a comfortable level, 30% were fairly satisfied, with 34% not satisfied they could heat their home to a satisfactory level.^[22]

40. In a poll commissioned in September 2022 by Independent Age of those over 65 with a household income below £20,000, 65% were worried they won’t be able to pay for gas, and 69% were worried they couldn’t pay for electricity. 74% admitted to cutting back on their heating, while 53% of participants also revealed that their current income negatively impacts their quality of life. ^[23]

41. Older households are less likely than families and other household types to report that their heating system doesn’t always keep them warm in winter; 18%, compared to 27% for both families and other households.^[24] These figures are similar to 2022, but represent an increase from 2019 levels.

42. Living in a cold home can be detrimental to many pensioners, due to reduced muscle mass and poorer circulation, they are not as physiologically able to keep warm during cold periods. There is also a strong relationship between cold homes and cardiovascular and respiratory disease.^[25] This can affect their immune systems which can amplify any pre-existing condition.^[26] Links between long term health conditions, poor health, wellbeing, and living in a cold, damp home is well recognised. In addition, there is also evidence on the mental health and wellbeing impacts of living in cold homes and experiencing fuel poverty, and the benefits to mental wellbeing which can be delivered from tackling fuel poverty across the age range.^[27]

43. Within our public consultation^[28], some respondents expressed concerns that older people in Scotland could receive less or lose out on funds compared to those in the rest of the UK if changes are made to the benefit in the future. Some respondents expressed concerns that targeting the benefit to those in receipt of Pension Credit could result in the exclusion of those just above the threshold to receive this benefit, but who are still in need of financial assistance.

Initial analysis provided by the Office of the Chief Economic Advisor suggests that the introduction of universal PAWHP will slightly increase the household income of those aged between 65-74, and those aged 75+, both in cash terms and as a proportion of income. The impact is very similar in both cash terms and as a proportion of income across the age groups affected with the introduction of universal PAWHP estimated to increase household income by around 0.25%.

44. The Scottish Government recognises that the proposed universal PAWHP does not fully mirror the universal WFP which was in place until 2023. Scottish Ministers assessed the finance available and concluded that the universal application of a higher payment rate, such as the £200–£300 payment rates under the previous universal WFP, is financially unviable within current budget constraints, especially in the context of expanding the scheme to all eligible pensioner households.

45. Pensioners who previously received £200 or £300 under the UK Government’s tiered universal WFP, which was available until winter 2023, and are not entitled to a higher rate of payment due to not receiving a relevant benefit, will now receive a lower flat-rate payment of £100. This will result in some recipients, especially those aged 80 and over and those living alone and not in receipt of a relevant benefit, receiving less support than was available under the previous universal WFP.

46. Under the previous UK system, households with individuals aged 80 and over received £300. Under the proposed universal approach, this higher payment amount has been maintained for those aged 80 and over in receipt of relevant benefits. As noted in the analysis above, individuals aged 80 and over are generally more vulnerable to the effects of cold weather and may have higher heating needs due to frailty, mobility issues, or health conditions. We have not been able to accommodate this factor under the new universal PAWHP eligibility. Whereas the previous universal WFP provided a higher rate of payment for those aged 80 and over, under the proposed universal PAWHP all pensioner households who are not in receipt of relevant benefits will receive a payment of £100, regardless of age. Although this represents an increase in the amount they are entitled to under the current restricted eligibility criteria, this represents a third of the support previously available under universal WFP. The removal of age-tiered rates may reduce the ability of the policy to target those most at risk of cold-related health impacts. The Scottish Government recognises this and will continue to monitoring outcomes and consider future changes, within available resources, to ensure that older pensioners receive adequate support during the winter months.

47. Nonetheless, Scottish Ministers concluded that the introduction of £100 payments to those pensioner households not in receipt of a relevant benefit provides wider universal access and administrative simplicity whilst remaining affordable, and goes some way to supporting those households towards meeting their heating bills throughout the winter. Recognising that there are many who are just above the payment threshold for relevant benefits who would benefit from support, rather than further targeting the payment by age, the Government has therefore taken a strategic decision to increase coverage at a lower payment level, aiming to support more households within a finite budget envelope, households who would not receive a payment under narrower targeting but nonetheless may require support. In addition to affordability and universality, this uniform payment will be simpler to implement, reduces the need for complex eligibility checks based on age bands, and reduces the risk of errors.

48. The extended PAWHP represents a significant positive policy change by restoring universal access to winter heating support for pensioners in Scotland. This aligns with the principles of equality and dignity and will benefit thousands of pensioners previously excluded. However, the decision to apply a flat-rate payment introduces a risk of unequal outcomes among the age group, particularly for the oldest pensioners. The Scottish Government recognises this and will take steps to engage with key stakeholders and monitor and address any unintended consequences over time.

49. A universal payment provides support to all pensioners, regardless of income or wealth. For those who do not wish to receive it, under our plans clients will be able to opt out of our universal PAWHP.

50. The process for opting out, and opting back in, has been designed ensuring there are as few barriers as possible to engaging in this process. Information in relation to opting out will be included in letters to clients and similarly, clients who have opted out will continue to receive communications from Social Security Scotland each year, which will notify them that they are not receiving a payment because they have opted out. This letter will also provide the client with the relevant information on how they can opt back in, should they wish to do so.

51. Data previously released by DWP under FOI indicates that in 2020/21 846 pensioners opted out of Winter Fuel Payment, and in 2021/22 186 pensioners opted out.^[29] It is therefore likely that only a very small fraction of eligible people will actively choose to opt out of PAWHP. Providing an opt-out and opt-in mechanism for PAWHP positively supports autonomy and choice for older people. Social Security Scotland will provide clear and accessible communication materials and, by providing the ability to opt back in we will ensure that an eligible pensioner will retain their ability to receive PAWHP in the future if they wish to do so. In addition, under section 26 of the Social Security (Scotland) Act 2018, a person has the right to stop receiving assistance and could ask for their determination of entitlement to be cancelled and return the payment.

52. Given the expansion of PAWHP to all people of state pension age, this approach will have a positive impact on vulnerable pensioners who are not eligible for Pension Credit or other eligible benefits, or who do not take up their entitlement to those benefits, but still face financial difficulties and would benefit from this support. It provides an efficient means of delivering support across Scotland’s pensioner cohort; helping to mitigate the increases in energy costs; and providing that cost-of-living support for all pensioner households, helping reduce pensioner poverty and support fixed pensioner household incomes. This policy is therefore expected to have a positive impact on the basis of age.

Disability

53. Poverty rates remain higher for households in which somebody is disabled compared to those where no-one is disabled. In 2021-24, the poverty rate after housing costs for people in households with a disabled person was 23% (550,000 people each year). This compares with 17% (510,000 people) in a household without disabled household members.^[30]

54. Fuel poor households with low levels of energy efficiency are more likely to have at least one member who has a long-term illness or disability (56%) when compared to non-fuel poor households in similarly inefficient homes (41%).^[31]

55. Evidence highlights that there is a relationship between long-term health conditions or disability and increasing age. The 2020 Scottish Health Survey found that the prevalence of any long-term condition increased with age, from 32% among those aged 16-44 to 68% among those 75 and over.^[32] The likelihood of being disabled/experiencing chronic and complex health conditions among those 65 and over increases with age.^[33]

56. In Consumer Scotland’s report on their findings about the impacts of energy costs on disabled people and people with health conditions, they highlight that disabled people, those with health conditions and their family carers are at greater risk of energy affordability challenges due to three linked factors:

• The high cost of energy combined with their high usage needs, especially for heating but also for a variety of other reasons related to people's individual requirements including powering medical equipment, having paid carers in the home etc
• Limited opportunity to reduce their energy use without experiencing detriment
• Having generally lower incomes and a higher cost of living

57. They also reflected that those of older age could be particularly affected because due to the intersection of their disability and age.

58. According to Consumer Scotland’s Energy Affordability Survey^[34], 68% of disabled people reported rationing their energy use, compared to 56% of non-disabled people. It was also highlighted that 41% of disabled people found it difficult to keep up with their energy bills in comparison to 24% of non-disabled people.^[35]

59. Within our public consultation, some respondents suggested that eligibility for PAWHP could be extended to adults with disabilities who are below pension age. These respondents highlighted that those with disabilities could benefit from support with heating costs, as they often need to maintain a higher household temperature and are likely to spend longer periods of time in their home.

60. Similarly, many responses to our Experience Panel survey on PAWHP suggested that a payment should be extended to adults with disabilities, as they may be affected by cold weather due to their condition or may spend longer periods within their home due to limited mobility, resulting in greater heating costs. Respondents also noted the additional costs associated with running healthcare equipment for disabled people.^[36]

61. Published data relating to disability of WFP recipients is not available. However, people in receipt of disability benefits have a higher Pension Credit income threshold than those without, and their disability benefit is not considered as income in the test for Pension Credit. So people in receipt of disability benefits can still claim Pension Credit - and therefore be passported to claim PAWHP - on higher incomes than those not in receipt of disability benefits.

62. This is reflected in analysis undertaken by the Office of the Chief Economic Adviser which indicates that 25% of State Pension recipients in Scotland claim one of the disability benefits: Attendance Allowance, Disability Living Allowance or Personal Independence Payment, and 62% of these also claim Pension Credit in Scotland, meaning those with a disability are more likely to continue to receive PAWHP at a higher rate than those without. Under current levels of Pension Credit take-up, around 66% of people on disability benefits and 93% of people not on disability benefits are not entitled to PAWHP under the restricted eligibility.^[37]

63. This analysis suggests that, for those households with a disabled member, the introduction of a universal household payment at a flat rate of £100 for those not in receipt of relevant benefits will result in an increase in household income of 0.24%.^[38]

64. By instating universal eligibility to PAWHP, disabled people of pension age who did not receive a relevant benefit and therefore were not eligible to PAWHP, will once again receive this guaranteed annual support. This policy is therefore expected to have a positive impact on the basis of disability, for those who are not claiming Pension Credit, when compared to the targeted policy.

Sex

65. Sex is a protected characteristic under the Equality Act 2010, meaning policies should not unfairly advantage or disadvantage men or women.^[39] As the introduction of the universal payment for PAWHP is targeted at pension age individuals, it is necessary to consider sex-based differences in life experience expectancy, income, and financial vulnerability.

66. Research shows us that female pensioners are more likely to live in poverty than male pensioners. This could be as a result of having fewer years of employment due to caring responsibilities and greater likelihood of lower paid and part-time work.^[40] In 2021-24, 23% of single female pensioners (60,000 women each year) were in relative poverty after housing costs, compared to 18% of single men.^[41]

67. Healthy Ageing in Scotland’s (HAGIS) Pilot Survey^[42] notes a substantial amount of older people live alone, with women more likely to live in a single household (44%) than men (30%). This means that men may have greater opportunity to share the responsibility for heating bills whereas more women will be solely responsible for heating their own home.

68. Analysis undertaken by the Office of the Chief Economic Adviser has indicated that as a proportion of income, there is a slightly greater benefit for single occupancy households. This is because single occupancy households have lower average household incomes. However, a higher proportion of single occupancy households compared to other household types receive a relevant benefit and therefore do not benefit from the £100 payment^[43] because they already receive payment at a higher amount. This means the average cash benefit is slightly lower for these households.

69. Since 2008 there has been a gradual increase in the proportion of adults reporting living with a long-term health condition, slightly more pronounced for women (42% in 2008 and 52% in 2022) than for men (38% in 2008 and 45% in 2022).^[44] Women were more likely than men to report having a limiting long-term condition (42% and 32% respectively). However, women tend to live longer. The most recent statistics tell us that the life expectancy in Scotland for men is 76.5 and 80.7 for women.^[45]

70. WFP statistics suggest that 54% of those who received a WFP in Scotland in 2023-24 were female, and 46% were male.^[46] Given the current take up of Pension Credit, 84% of women receiving a WFP are expected to have lost entitlement under the restricted eligibility criteria, compared to 91% of men. Men were therefore marginally more likely to be affected by the change to PAWHP eligibility, and so are more likely to gain from the introduction of the universal element of PAWHP. However, women who are not currently receiving a relevant benefit will also benefit from the universal payment.

71. The introduction of universal eligibility to PAWHP will ensure that pensioners receive guaranteed annual support with their heating bills, regardless of their sex. Under our universal PAWHP, a person living alone or with no other eligible person, will receive £100. For those living with another eligible person, a shared rate payment of £50 will be provided. We therefore do not anticipate any significant impact on the basis of sex.

Gender reassignment and sexual orientation

72. The 2022 Census found that there were 19,970 trans people in Scotland. This is 0.44% of people aged 16 and over.^[47] For those 65 and over, the 2022 census found that 1190 people were trans or had a trans history.^[48]

73. When considering access to benefits, we recognise that a requirement for an individual to provide their gender when making an application may be a potential barrier to trans people and those who identify as non-binary. Non-binary people in particular can be excluded if individuals are asked to tick a box to indicate their gender and only binary options are available. This was reiterated by LGBTI youths throughout previous Scottish Government consultation engagement for CWHA - those who had undergone gender reassignment discussed feelings of being ‘outed’ by such processes as they had to reiterate that they had changed gender.

74. The Scottish Trans and Non-Binary Experiences Summary Report 2024^[49] reported key findings on socio-economic issues for trans and non-binary respondents to their self-selection survey. The survey asked about the cost-of-living crisis and access to benefits for trans and non-binary individuals aged 16+. The survey reported that 33% of respondents were claiming benefits. A majority of respondents (75%) felt their trans status, history or gender identity had not made it harder to receive benefits. But 7% felt it had, and 18% were unsure. In relation to the cost of living, the report also found that 52% of respondents said that rising costs had caused them to need to make decisions between essential household purchases and purchases relating to their transition.

75. The report also highlighted challenging experiences for trans and non-binary people trying to access DWP benefits, particularly around their records being deemed sensitive. The report outlined that “Due to the DWP/HMRC badly designed “special customer” system that they put trans people’s files into in order to restrict access to trans history info, it is extremely difficult to get help with benefit claims and tax issues as staff cannot see your file when you phone up. Also, the “special customer” restriction causes you to fail any online automated checks using your NINO to prove your identity.”

76. Evidence provided by Social Security Scotland client diversity and equalities analysis^[50] demonstrated that trans clients had a slightly lower approval rate for benefits than clients who were not trans across all benefits. However, there was some variation in approval rates across specific benefits. For ‘Best Start Grant and Best Start Foods’ and Scottish Child Payment, approval rates were 51% and 75% for transgender clients, compared to 62% and 81% for clients that were not transgender. In contrast, the Adult Disability Payment, clients that identified as transgender had a higher approval rate at 63% compared to clients that did not identify as transgender at 55%. Although there were larger differences in approval rates for other benefits, the number of transgender clients were too low to make reliable comparisons of approval rates.

77. The data shows that it is evident there are some barriers faced by clients who are non-binary or trans when accessing and claiming benefits. When Social Security Scotland deliver PAWHP from 2025/26, it will remain an automated payment for the vast majority of eligible recipients and therefore very few people will need to make an application. Where applications are required, a person will not be required to provide their gender. However, anyone that does apply is asked to voluntarily provide this information for statistical purposes only.

78. The design of our systems and the training of our staff will ensure that regardless of who the applicant or client is, they will be treated respectfully. Agency staff will be recruited and trained to embody values of dignity and respect and all training for new staff will include LGBTI awareness and be underpinned by human rights principles.

79. We do not anticipate anyone to be negatively impacted by the introduction of universal eligibility for PAWHP on the basis of gender re-assignment or sexual orientation.

Religion or belief

80. We have not identified any particular barriers resulting from our policy approach which may affect people with the protected characteristic of religion or belief.

Pregnancy and maternity

81. As our benefit will be paid to people of pension age, we do not believe pregnancy and maternity status to be a significant factor for our target group.

Race

82. Race is a protected characteristic under the Equality Act 2010.^[51] The introduction of the universal element of PAWHP should be assessed for the impact on the diverse racial communities living in Scotland.

83. At the time of the 2022 census, 87.1% of Scotland’s population identified as “white” “Scottish” or “Other British”, while 12.9% identified as belonging to another ethnic group.^[52] In 2022, 5% of Scotland’s population communicated in a “main language” other than English.^[53]

84. Over the five year period from 2018-23 people from non-white minority ethnic groups were more likely to be in relative poverty after housing costs compared to those from the ‘White - British’ and ‘White - Other’ groups. The poverty rate was 50% for the ‘Asian or Asian British’ ethnic groups and 51% for ‘Mixed, Black or Black British and Other’ ethnic groups (no population estimates available due to the small sample). The poverty rate amongst the ‘White - Other’ group was 22% (80,000 people) and that of the ‘White - British’ group was 18% (840,000 people).^[54]

85. Research indicates that people from various ethnic minorities are more likely to experience health conditions that require a greater need for household heat, and so are at greater risk of higher levels of fuel poverty.^[55]

86. Pensioners from Black and Asian communities are around twice as likely as white pensioners to be living in poverty, with 33% Asian, and 30% Black pensioners living in poverty, compared to 16% white pensioners.^[56]

87. Based on data from the 2022 Census for households, for those aged 65 and over, minority ethnic groups such as African (African, African Scottish or African British), those of mixed or multiple ethnic groups, and White (Gypsy/Traveller) are more likely to have no central heating. Minority groups such as White (Gypsy/Traveller), Caribbean or Black, and African (African, African Scottish or African British) were more likely to have electric central heating, while those with mixed or multiple ethnic groups, Caribbean or Black, and White (Gypsy/Traveller) were more likely to have two or more types of central heating. The census data suggests that the minority ethnic groups White (gypsy/traveller), White Other (including Irish, Polish and Other White and Other White British), and those of mixed or multiple ethnic groups, are less likely to have gas central heating.^[57]

88. A universal PAWHP will ensure that all pensioners in ethnic minority households are supported to meet some of their heating costs during the winter months, regardless of central heating source.

89. When considering the Gypsy/Traveller community, Gypsy/travellers are more likely to have one or more long-term health conditions. 37% reported at least one health condition, compared to 30% of the population as a whole, and are twice as likely to report three or more health conditions (6% compared to 3% among the rest of the population).^[58]

90. The 2022 Census results show that, where the household reference person is aged 65 or older, 4% of the White: Gypsy/Traveller community have no central heating, in comparison to 2% respectively for all other households^[59]. In relation to gas central heating, 62% of the White: Gypsy/Traveller community have gas central heating in contrast to all other households at 73% respectively.

91. Within our PAWHP Experience Panel survey, some respondents highlighted that groups such as gypsy/travellers may need additional support with heating costs due to their living condition or type of housing.^[60]

92. Similarly, within our public consultation some respondents emphasised that many within the gypsy/traveller community do not have access to a bank account. Respondents highlighted the importance of flexible payment arrangements, to ensure that this group is not unfairly disadvantaged.^[61]

93. We recognise that the payment method will be important for some people and particularly gypsy/traveller communities. Payments can be made in a range of ways - into a UK bank or building society account or into someone else’s account that they can access, or through using i-Movo (New Payment Exception Service) which is a secure digital voucher system that can be delivered to individuals in several media (SMS, email). These can be redeemed at PayPoint outlets across Scotland.

94. PAWHP is an automatic payment for the vast majority of clients, with an application only required in very specific circumstances. This automated approach should reduce any additional challenges to accessing this benefit.

95. Furthermore, Social Security Scotland will create a bank of PAWHP stakeholder resources and content, in accessible formats, available to stakeholder organisations, to distribute to people in local communities. The languages we proactively translate materials into were selected through stakeholder consultation. These are: Arabic, Farsi, Gaelic, Kurdish Sorani, Lithuanian, Polish, Romanian, Russian, Slovak, Traditional Chinese, Ukrainian, Urdu, BSL. Benefit information is also available in Easy Read format. We can translate into other languages and formats on request, including Braille.

96. Social Security Scotland will produce communications materials in other languages on request. In some circumstances, printed marketing materials may not be the right way to engage with these communities and, where this is the case, we will provide an engagement approach through the Strategic Stakeholder Engagement and Partnership and Events teams.

97. National Carer Organisations advocated in their consultation response for accessible resources to be produced to benefit ethnic minority groups, recommending the Minority Ethnic Carers of People Project (MECOPP) briefing on Producing Accessible Information for BME Communities as a useful tool for this.

98. While it is clear that older people from ethnic minority communities experience numerous barriers, we have not identified any particular barriers resulting from our policy approach which may affect people based on race.

99. The introduction of universal PAWHP will benefit all pensioner communities in Scotland. All pensioners who didn’t receive a payment under the restricted scheme in 2024/25, will receive a payment to help them with their heating costs during the winter months.

Marriage and Civil Partnership

100. Marriage and Civil Partnership is a protected characteristic under the Equality Act 2010. ^[62] We should therefore consider the different impacts of introducing PAWHP depending on people’s marriage or civil partnership status.

101. In data published for 2019-22, married adults were the least likely to be in poverty.^[63] Analysis from Age UK shows that single female pensioners (27%) have a much higher risk of being in poverty than single men (23%), and pensioner couples (13%).^[64]

102. Using the Family Resources Survey data, approximately 40% of those who received a WFP in 2022-23 were single. Those in a couple (96%) are more likely to lose out under the restricted PAWHP eligibility than single people (74%). This may be partly explained by the fact that, since 2019, mixed-age couples (where one person is below state pension age) can no longer apply for Pension Credit. Analysis suggests that some of these mixed-age couples are not able to get Universal Credit and therefore miss out on PAWHP under the restricted eligibility criteria.

103. The introduction of universal eligibility for PAWHP would therefore positively impact some mixed-age couples, ensuring a guaranteed PAWHP payment for those who may otherwise miss out due to the restrictions on claiming Pension Credit when in a mixed age couple.

104. As noted previously, analysis carried out by the Scottish Government on the impact of the universal PAWHP shows that as a proportion of income, there is a slightly greater benefit for single occupancy households. This is because single occupancy households have lower average household incomes. A higher proportion of single occupancy households compared to other household types receive a relevant benefit and therefore do not benefit from the £100 payment. This means the average cash benefit is slightly lower for these households.^[65]

105. Under our universal PAWHP, for those not in receipt of a relevant benefit, a person living alone or with no other eligible person, will receive £100. For those living with another eligible person, a shared rate payment of £50 will be provided to each member of the household. This will ensure each eligible person receives support and reflects the way in which WFPs have been delivered previously.