Questions 21 to 27: Timing of 'Qualifying Week' and Payment
Sections 5.7 and 5.8 of the consultation set out our proposals that LIWHA be paid as a single annual payment in February and that eligibility to receive the payment be established during a qualifying week in September. During that week DWP would identify the individuals receiving the benefits which entitle recipients to a CWP when a cold spell occurs.
Use of a Qualifying Week to establish eligibility
Basing LIWHA eligibility solely on receipt of low income benefits requires us to specify the point or points in time at which eligibility will be determined. We consulted on a proposal to establish a qualifying week during which we would establish, through data from DWP, all households in receipt of specified qualifying benefits who would subsequently receive an automatic LIWHA payment. This is the approach taken to establish eligibility for DWP's Winter Fuel Payment (WFP) and the Scottish Government's Child Winter Heating Assistance (CWHA).
Some respondents suggested extending the period within which eligible clients are identified to cover the whole of the winter, or to have multiple periods throughout the winter where eligibility is determined. As we rely on DWP to provide details of eligible clients, the introduction of multiple points in time in which data would be required adds significant complexity, increases the risk to delivery and would require DWP agreement. Alternative solutions to the provision of a single data extract from DWP would not be able to be delivered in time to launch LIWHA in winter 2022-23.
Timing of a Qualifying Week
We suggested in the consultation that the qualifying week be set for the third week in September, to be consistent with other winter heating benefits being paid across the UK. Some respondents highlighted that this would lead to a significant gap in time between determining entitlement and making payments. We have therefore decided that the proposed single qualifying week will now take place at the beginning of the winter period in November each year. This will bring the timing of the qualifying week closer to the payment date in February 2023 and will still provide sufficient time for DWP to extract and consolidate data and transfer it to us before we prepare it for processing.
With the existing CWHA, the introduction of LIWHA, and our replacement for WFP in winter 2024-25, Social Security Scotland will be responsible for benefits payable to around 1.5 million clients in Scotland each winter. As it is likely that the qualifying week required for the WFP replacement will be scheduled for September each year, reflecting the current WFP and CWHA, a November qualifying week for LIWHA will reduce the pressure on operational capacity and enable us to conduct the necessary testing of data received from DWP to allow payments to start being made to clients in February 2023.
Annual Payment in February
The consultation proposed a single payment each February, identified as one of the coldest months during the winter where historically a high number of CWPs have been made.
The majority of respondents to the consultation consider that a payment in February would be too late, particularly for households using pre-payment meters who would risk accumulating debt with their energy providers. Again this reflected the responses to our Experience Panel survey, which showed that less than half of respondents agreed the benefit should be paid in February. Even though this is traditionally one of the coldest months in Scotland, many people thought the benefit should be paid earlier. It was suggested that households who are not connected to the national gas grid, and need to buy fuel in advance, would be disadvantaged.
Commencing payments in February 2023 will provide Social Security Scotland with a small window of time in which to manage any issues arising from the extension of Scottish Child Payment (SCP) and to train staff needed to support the launch of LIWHA. It also provides Social Security Scotland time within the crucial test window to test the actual client data from DWP in the live data assurance environment. These tests are performed to ensure the system is working as expected and to ensure the maximum amount of automation can be applied to the LIWHA data cohort.
Making payments in February for the initial year that LIWHA is launched will ensure a smooth transition from CWP to LIWHA. However while we will explore the feasibility of bringing forward the payment date in future years we cannot do so for winter 2022-23.
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