Social Security Experience Panels: Pension Age Winter Heating Payment

2. Survey Findings

2.1 - Replacing Winter Fuel Payment with Pension Age Winter Heating Payment

The Scottish Government has committed to replacing the DWP-delivered WFP with Pension Age Winter Heating Payment on a like-for-like basis. This means continuing eligibility for all those who have previously been eligible for WFP. Eligibility for WFP is linked to an individual's age (reaching state pension age).

The main objective of PAWHP is to provide all older people with support with the costs of heating their homes throughout the winter. Older people are targeted because they may be particularly vulnerable to the effects of cold weather during the winter months and are more likely to be on fixed incomes.

As it is a universal benefit that is paid automatically, the take-up for WFP is very high, with 96 per cent of the eligible population receiving a WFP in 2021/22.

Under PAWHP, everyone in Scotland who would currently be eligible to receive WFP would continue to receive the same level of support. The Scottish Government's intention is that this payment will continue to be non-means tested and tax free. This will provide universal support to pension age people to help them keep their homes warmer throughout the winter.

The majority of respondents (71 per cent) agreed with the proposal to replace the WFP with a 'like-for-like' replacement under Social Security Scotland. Only ten per cent disagreed (Table 2.1).

Table 2.1 – Do you agree or disagree with the proposal to replace Winter Fuel Payment with a 'like-for-like' replacement? (n=164)

	Percentage (%) of respondents*
Agree	71
Disagree	10
Neither agree nor disagree	18

*Figures may not add to 100 per cent due to rounding.

Survey respondents were informed that the Scottish Government are proposing to call the new benefit 'Pension Age Winter Heating Payment,' to help people identify the purpose of the payment and who it is aimed at.

Almost three quarters (72 per cent) of respondents agreed with the proposed name of 'Pension Age Winter Heating Payment'. However, slightly more than a fifth (21 per cent) disagreed (Table 2.2).

Table 2.2 – Do you agree or disagree with naming the replacement for Winter Fuel Payment in Scotland 'Pension Age Winter Heating Payment'? (n=163)

	Percentage (%) of respondents*
Agree	72
Disagree	21
Neither agree nor disagree	7

*Figures may not add to 100 per cent due to rounding.

One respondent commented that they disagreed with this name as they felt that the payment should be means tested and applied more broadly to vulnerable groups, not just pensioners, and that the name should reflect this.

"I disagree that it should be called Pension Age Winter [Heating Payment] as disabled people who often struggle are vulnerable too. I believe it should be called something more along the lines of Vulnerability Fuel Payment if changing and should be applied to those eligible through age/income and be means tested." (Survey respondent)

Respondents were also asked if they thought that the proposed format for PAWHP would be an effective way for the Scottish Government to provide financial support to older people. More than four-fifths (83 per cent) of respondents agreed (Table 2.3).

Table 2.3 – Do you think that PAWHP is an effective way for the Scottish Government to provide financial support for older people? (n=162)

	Percentage (%) of respondents*
Yes	83
No	11
Don't know	6

*Figures may not add to 100 per cent due to rounding.

2.2 – Timing of payment

WFP is currently paid automatically to eligible recipients during November or December, making payments into individuals' bank accounts just before the coldest winter weather is likely. The Scottish Government is proposing to continue with this payment window for Pension Age Winter Heating Payment.

When asked about the timing for the payment, the majority (80 per cent) of respondents said that the current November – December payment window was the most suitable (Table 2.4).

Table 2.4 – Thinking about your own heating needs, when would be the most useful time for you to receive a winter fuel payment? (n=160)

	Percentage (%) of respondents*
The current payment window (November – December)	80
Earlier than this	13
Later than this	7

*Figures may not add to 100 per cent due to rounding.

Respondents with a physical disability were more likely to prefer the current payment window (Table 2.5), with nine in ten (90 per cent) selecting this option. Respondents without a physical disability were less likely to prefer the current payment window. For example, more than a quarter (26 per cent) of respondents without a physical disability preferred an earlier payment window.

Table 2.5 – Differences in response by respondents with or without a physical disability, percentages*

When would be the most useful time for you to receive a winter fuel payment?	Has a physical disability (n=73)	No physical disability (n=35)
Current payment window	90%	63%
Earlier than this	4%	26%
Later than this	5%	11%

*Figures may not add to 100 per cent due to rounding.

These findings were mirrored for older respondents (Table 2.6), where almost nine in ten (87 per cent) respondents aged 60 or over preferred the current payment window, compared to less than three-quarters (71 per cent) of those aged 45-59 years old.

Table 2.6 – Differences in response by respondents' age group, percentages*

When would be the most useful time for you to receive a winter fuel payment?	45-59 years old (n=31)	60+ years old (n=67)
Current payment window	71%	87%
Earlier than this	13%	9%
Later than this	16%	4%

*Figures may not add to 100 per cent due to rounding.

Maintain current payment window

A few respondents provided comments in support of keeping the current payment window, referencing the need to minimise disruption.

"Keep the payment timetable as it is; people mostly understand the timing of the current payment. Any change would need explaining and implementing." (Survey respondent)

Others commented that while they think the current window is the most suitable, it is important for the payment to be delivered as early as possible, in order to have money available to pay bills or purchase fuel in advance of cold weather.

"We always buy more coal when the weather gets cold. We have just increased our coal order (November). This is a good time to get the payment." (Survey respondent)

"Stick to the current window. I received a cold weather payment from the Scottish Government this year, MONTHS after having paid the relevant bill." (Survey respondent)

Earlier payment window

Respondents gave diverse reasons for preferring an earlier payment window. Some stated that cold weather, or the need to have the heating on, can occur earlier in the year.

"Our heating has been on since start of October, so an earlier payment would be appreciated." (Survey respondent)

"I think October can also be a very cold month. Particularly for pensioners with little or no mobility." (Survey respondent)

Others suggested that an earlier payment would help with buying fuel in advance of the colder weather for those who are off-gas grid and may face additional supply issues, such as rural or island households.

"Heating is necessary in rural areas from start of October and I like to get my tank filled before the cold weather starts. We have to pay for our heating before we use it and it is expensive." (Survey respondent)

"As I am off grid a payment in October would be better for ordering fuel as it gets more difficult to get deliveries in November/December due to the number of deliveries in the area." (Survey respondent)

Some respondents also suggested that the payment should be linked to the cost of fuel, allowing people who are off-gas grid to purchase fuel when costs are lower before winter price rises.

"Pay the allowance earlier to allow pensioners to be able to plan for example, to buy heating oil in advance before the usual winter oil increase knowing they have the winter heating payment in the bank in advance of the winter months." (Survey respondent)

Later payment window

Respondents who preferred a later payment date suggested a variety of reasons for why they would find this more suitable. The most common was that the worse weather was experienced later in the winter around January and February, making this the time of year when heating would be used more and household costs higher.

"I'd expect to have higher heating expenses later in the winter so the money would be more use then." (Survey respondent)

"I understand January and early February to be the coldest time of year so ideally the payment would be made in early to mid-December." (Survey respondent)

A few respondents suggested that receiving the payment later would allow people to manage their finances better, through avoiding spending the money in the Christmas period or using the heating before colder weather sets in.

"Yes, as an adviser (Citizens' Advice Bureau) early new year/February would be a better payment month as I experienced November payments were used for Christmas shopping not kept for higher heating bills in January – March." (Survey respondent)

"If the payment comes too early I'd be less frugal with heating in early winter. If a cold spell hits later in the winter this would allow me to increase heating while not worrying so much about financial costs." (Survey respondent)

Other suggestions

There were other suggestions made regarding the timing of the payment that were not linked to earlier or later payments. Some respondents wanted to see the timing of the payment linked to the first spell of cold weather in the winter, and for this to be differentiated by area e.g. island communities.

"It could be a flexible window depending on the timing of winter weather, particularly for Island communities." (Survey respondent)

Other respondents said that they would find it useful to have advance notification of when the payment was going to be delivered, or if there were going to be any delays.

"Being informed of any delay to payment." (Survey respondent)

"Exact dates notified to anyone receiving the payment at least two weeks before payment so that those having to use oil, gas cylinders and solid fuel can order in advance so that they are not panicking about having enough winter fuel." (Survey respondent)

A few respondents suggested that as costs for fuel have risen the payment now needs to be paid more than once.

"Costs are now high and need to be paid perhaps twice per year." (Survey respondent)

Others suggested splitting the payment into instalments instead of providing it as one lump-sum.

"Could the payment be split? E.g. three instalments to help people manage rather than one whole payment early in the winter." (Survey respondent)

2.3 – Eligibility and qualifying week

As described above, WFP is a universal payment that is linked to an individual reaching state pension age. The Scottish Government does not intend to make changes to the criteria that establishes entitlement to Pension Age Winter Heating Payment and Scottish Ministers have committed to not means testing or taxing the payment. Therefore, those clients who are currently eligible for WFP due to reaching state pension age will automatically be eligible for a PAWHP payment.

Link to state pension age

Survey respondents were asked for their views on Pension Age Winter Heating Payment remaining linked to an individual reaching state pension age. Over two-thirds (69 per cent) of respondents agreed. However, just over a fifth (21 per cent) disagreed (Table 2.7).

Table 2.7 – Do you agree or disagree that eligibility for PAWHP should remain linked to state pension age? (n=157)

	Percentage (%) of respondents*
Agree	69
Disagree	21
Neither agree nor disagree	10

*Figures may not add to 100 per cent due to rounding.

There was a clear divide by age in responses to this question. More respondents aged 45-59 disagreed (42 per cent) that PAWHP should remain linked to state pension age, compared to only one in ten (10 per cent) of those aged over 60 (Table 2.8).

Table 2.8 – Differences in response by age, percentages*

Do you agree or disagree that eligibility for PAWHP should remain linked to state pension age?	45-59 years old (n=31)	60+ years old (n=67)
Agree	39%	81%
Disagree	42%	10%
Neither agree nor disagree	19%	9%

*Figures may not add to 100 per cent due to rounding.

Some respondents commented that they would like the qualifying age to be lowered, citing similar needs and concerns for people below pension age to those above it.

"[PAWHP] should be paid to everyone when they reach the age of 60. People aged 60 have the same needs as someone aged 67." (Survey respondent)

"Please consider others in desperate need of this payment […] as we cannot afford to heat our homes. I am 59 and living cold, in fear of every winter." (Survey respondent)

Further comments regarding expanding the eligibility criteria for PAWHP are covered later in this report under sections 2.5 and 2.6.

Qualifying week

Eligible clients for winter fuel payments are identified and paid automatically if they meet the qualifying criteria during the qualifying week, which is currently in September each year.

The Scottish Government is proposing to maintain the current timetable for having the qualifying week in September. Four-fifths (80 per cent) of respondents agreed with this (Table 2.9).

Table 2.9 – Do you agree or disagree with having the 'qualifying week' to identify eligible clients in September? (n=148)

	Percentage (%) of respondents*
Agree	80
Disagree	13
Neither agree nor disagree	7

*Figures may not add to 100 per cent due to rounding.

While the majority of survey respondents supported the current timing for the qualifying week, no written responses were received clarifying the reasons for supporting this. One respondent commented that they supported the current timing but wanted to see this used to give advance notification of the payment to recipients.

"I think September is ok and it gives you time to contact eligible people before November, so they know they will receive payment." (Survey respondent)

Extend qualifying period

The Scottish Government has noted in the consultation on Pension Age Winter Heating Payment that a later qualifying week would reduce the number of people who 'miss out' on the payment in their first winter, due to not meeting the age criteria at the time of this qualifying week (e.g. those who have a birthday in October).

However, the work involved in identifying eligible clients and determining the correct rate of payment for each person means that late September is the latest possible date for establishing entitlement in order to make payments in time for that year.

Although this information was noted in the survey, extending the qualifying period remained the most common suggestion from survey respondents. A variety of reasons were given for this. Respondents stated that they felt it was unfair for people whose birthdays fell just outside the qualifying week to miss out on the payment for that winter.

"People whose birthday is a few weeks behind the qualifying date miss out for a whole year with help despite moving into state pension." (Survey respondent)

Some suggested that there could be an extended window for those who have birthdays close to the qualifying week, or that there could be an option for these people to make a manual application for PAWHP.

"Seems unfair. Could you not do a separate scan later for those birthdays [in] October to December?" (Survey respondent)

"There must be a cut-off date, but you should extend for those birthdays October to December to claim via paper form. It's [a] shame folk lose out by a day or week." (Survey respondent)

Similarly, one respondent suggested that the qualifying period should be extended for those who have birthdays close to the qualifying week and are living in poverty, to allow them to make an application for support.

"Agree for overall system BUT think anyone eligible for their State Pension within the following six months [up] to end of the financial year on 5th April, who is living in poverty should be eligible to apply for the payment as being "under special circumstances"." (Survey respondent)

Change in circumstances

Some survey respondents disagreed with the use of a qualifying week as they felt that it risked excluding people who may have a change of circumstances which changed their eligibility for the payment (see section 2.4). For example, a prisoner who is released shortly after the qualifying week period.

"The use of a qualifying week risks alienating and excluding those who may have a temporary or short change in circumstances, but may qualify for the other 51 weeks of the year." (Survey respondent)

"Consider the case of someone who is in prison or hospital at the time of the determination of eligibility but who may be in their own accommodation shortly thereafter or within the current winter period. How can they claim heating support?" (Survey respondent)

Other suggestions

A few survey respondents made other suggestions, such as extending the payments out over the whole year or using different timings for the qualifying week.

"I think the pension age clientele should be in receipt of winter fuel payments spread throughout the year as heating is vital not just in winter." (Survey respondent)

"Must be more around July, [to] be sorted and prepared for administration and disposal within November/December." (Survey respondent)

"Qualifying week January 1st and payment February or March." (Survey respondent)

One respondent stated that they found the term 'qualifying week' difficult to understand.

"Difficult to understand what a qualifying week is. The term is ambiguous. Suggest clearer, simpler language." (Survey respondent)

2.4 – Eligibility criteria and value of payments

The Scottish Government intend to maintain the current WFP values of payments for Pension Age Winter Heating Payment when it is introduced. The amount an individual will get paid depends on their household circumstances (Table 2.10).

Table 2.10: Eligibility criteria for different value of payments

Circumstance	Aged 66–79	Aged 80+
You qualify and live alone (or live with someone who does not qualify for PAWHP).	£200	£300
You qualify and live with someone under 80 who also qualifies.	£100	£200
You qualify and live with someone 80 or over who also qualifies.	£100	£150
You qualify, live in residential care and you do not receive certain benefits (e.g. Pension Credit)	£100	£150
You qualify, live in residential care and you do receive certain benefits (e.g. Pension Credit)	£0	£0

Survey respondents were asked how clear and easy to understand they found the criteria for different values of payment. Most respondents (70 per cent) agreed that the eligibility criteria were clear. However, just over one in ten (14 per cent) disagreed (Table 2.11).

Table 2.11 – The eligibility criteria are clear and easy to understand (n=155)

	Percentage (%) of respondents*
Agree	70
Disagree	14
Neither agree nor disagree	16

*Figures may not add to 100 per cent due to rounding.

Information accessibility

A few respondents commented that there needs to be better provision of information regarding winter fuel payments. One respondent suggested that there should be multi-lingual information materials available.

"I would make sure that local Mosques and religious centres have the details in Punjab or Urdu available for some of their older people to take away with them, in case they haven't heard of it." (Survey respondent)

Another stated that they found the information too complicated to understand.

"This is SO complicated, elderly and disabled people cannot understand all this, written by experts, professionals, and young people, little wonder many just cannot understand all this." (Survey respondent)

Value of payments

There was no clear consensus on the value of the payments, with mixed responses. Slightly more respondents agreed (41 per cent) than disagreed (34 per cent) that the value of payments was appropriate (Table 2.12).

Table 2.12 – Do you agree or disagree that the value of payments is appropriate? (n=154)

	Percentage (%) of respondents*
Agree	41
Disagree	34
Neither agree nor disagree	25

*Figures may not add to 100 per cent due to rounding.

However, there was a clear distinction between responses from respondents who live in different locations. Slightly more than half (51 per cent) of urban respondents agreed that the value of payments is appropriate, compared to only 15 per cent of rural respondents. In contrast, more than half (52 per cent) of rural respondents disagreed that the value of payments is appropriate (Table 2.13).

Table 2.13 – Differences in response by respondents' location (urban/rural), percentages* (n=27-87)

Do you agree or disagree that the value of payments is appropriate?	Urban (n=87)	Rural (n=27)
Agree	51%	15%
Disagree	26%	52%
Neither agree nor disagree	23%	33%

*Figures may not add to 100 per cent due to rounding.

Higher value of payment

Some survey respondents suggested that the value of the payment should be higher, referencing increasing costs of living over time. One respondent suggested that the value of the payment should vary by the income of the recipient.

"I would like this benefit linked to the pensions triple lock." (Survey respondent)

"I feel the payments should be higher for people on low incomes than people who have higher incomes. The amount hasn't been changed for a long time and should be brought in line with current costs." (Survey respondent)

People in residential care

As outlined in Table 2.10, under the current eligibility criteria for WFP people who are living in residential care during the qualifying week, and the period of 12 weeks immediately before the qualifying week, do not qualify for the 'full' payment rate. This is because they share the accommodation with other people who are also entitled to the payment and are responsible for a share of the heating costs.

If someone is living in residential care and receives Pension Credit, then they will not receive a payment. This is because historically people living in a care home and in receipt of an income-related benefit, such as Pension Credit, have received funding from the local authority for their care and accommodation costs, including heating. As this is still the case for the vast majority of people receiving Pension Credit, the WFP is not payable. The Scottish Government is proposing to continue with these eligibility rules.

Survey respondents were asked for their views on maintaining the values of payments for people in residential care, with almost two-thirds (65 per cent) in agreement (Table 2.14).

Table 2.14 – Do you agree or disagree with the payment rate for people living in residential care? (n=153)

	Percentage (%) of respondents*
Agree	65
Disagree	16
Neither agree nor disagree	18

*Figures may not add to 100 per cent due to rounding.

Respondents who had caring responsibilities were more likely to agree with the payment rate for those in residential care when compared to non-carers (Table 2.15). Almost three-quarters (73 per cent) of carers agreed, compared to around three-fifths (58 per cent) of non-carers.

Table 2.15 – Differences in response by carers and non-carers, percentages* (n=43-64)

Do you agree or disagree with the payment rate for people living in residential care?	Carer (n=64)	Non-carer (n=43)
Agree	73%	58%
Disagree	17%	16%
Neither agree nor disagree	9%	26%

*Figures may not add to 100 per cent due to rounding.

Around three-fifths (61 per cent) of respondents agreed that people in residential care who are in receipt of Pension Credit should not receive PAWHP (Table 2.16). However, a fifth (20 per cent) disagreed.

Table 2.16 – Do you agree or disagree that people living in residential care who are in receipt of Pension Credit should not receive PAWHP? (n=153)

	Percentage (%) of respondents*
Agree	61
Disagree	20
Neither agree nor disagree	19

*Figures may not add to 100 per cent due to rounding.

Two respondents expressed concern over how the eligibility rules would affect those who are self-funding their residential care, or who may still have financial obligations linked to home ownership.

"Not sure of consideration/impact on people in residential care, not on [Pension Credit], who are self-funders and whose assets are dwindling." (Survey respondent)

"People in residential care can still need to pay bills on their main home if they are a sole occupier." (Survey respondent)

Other exclusions

Respondents were informed about other exclusions that apply for WFP which would result in no award, and which the Scottish Government intends to reflect for PAWHP. These include if the individual has been in hospital for more than a year or is in prison throughout the qualifying week, where public funding will cover the costs of heating accommodation. Three-fifths (60 per cent) of respondents agreed with this proposal, however more than a quarter (28 per cent) neither agreed nor disagreed (Table 2.17).

Table 2.17 – Do you agree or disagree with the other exclusions to PAWHP mentioned above? (n=152)

	Percentage (%) of respondents*
Agree	60
Disagree	13
Neither agree nor disagree	28

*Figures may not add to 100 per cent due to rounding.

As noted in section 2.3, a few survey respondents expressed concern over the exclusion of individuals who may have a change in circumstances, such as leaving hospital or prison after the qualifying week period.

Receiving the payment

The Scottish Government is proposing to continue to pay clients PAWHP automatically on an annual basis. Clients would be identified and paid through the system which processes their State Pension or other benefits. For the vast majority of people there will be no need to apply and payments would be made automatically into a client's bank account.

Almost all (91 per cent) survey respondents agreed that PAWHP should continue to be provided as a one-off payment each winter (Table 2.18).

Table 2.18 – Do you agree or disagree with the proposal to pay PAWHP as an annual one-off payment each winter? (n=153)

	Percentage (%) of respondents*
Agree	91
Disagree	7
Don't know[3]	3

*Figures may not add to 100 per cent due to rounding.

Similarly, almost all (95 per cent) survey respondents agreed that PAWHP should be provided as a cash payment directly into a client's bank account (Table 2.19).

Table 2.19 – Do you agree or disagree with PAWHP being provided in the form of a cash payment, directly into a client's bank account? (n=154)

	Percentage (%) of respondents*
Agree	95
Disagree	4
Don't know	1

*Figures may not add to 100 per cent due to rounding.

A few respondents offered comments as to why they disagreed that PAWHP should be provided in a one-off payment in this manner. As noted earlier in section 2.2, some respondents suggested that the payment should be split into instalments or provided more than once a year.

One respondent queried what happens if an individual does not have a bank account for the payment to be made into. Others suggested that the payment could be sent directly to energy suppliers, rather than recipients' bank accounts.

"What about people who have no bank account?" (Survey respondent)

"I would have preferred a payment made to the utility company rather [than] a cash payment as a heating allowance. Some claimants do not use the payment for heating and spend it on other uses. Last year's scheme to help pay electric bills was a direct payment system to utility companies, an idea to consider with Scottish payments." (Survey respondent)

Similarly, another respondent suggested that off-gas grid households could have the payment sent directly to their fuel supply company, to potentially allow discounts across bulk orders.

"Pay it directly to our oil account holders that way maybe [we'll] get better price in bulk orders." (Survey respondent)

Finally, one respondent also suggested that people should receive advance notification of the timing and value of the payment to allow enough time for addressing and resolving any issues.

"Clients should have visibility online of the payment they are due well in advance with the capability to query any error for correction within 14 days." (Survey respondent)

Opting out

As PAWHP is a universal payment for older age people, the Scottish Government knows that there will be some people who may not require additional support during the winter due to having a higher level of income. DWP currently provide an option to opt-out of receiving WFP if the eligible person does not wish to receive it or alternatively suggest people can donate it to a charity of their choice.

The Scottish Government intend to mirror this approach and provide the opportunity to opt-out of the PAWHP payment ahead of the winter period. Almost nine in ten (88 per cent) survey respondents agreed that people should be able to opt out of receiving the payment (Table 2.20).

Table 2.20 – Do you agree or disagree that people should be able to opt-out of receiving PAWHP? (n=152)

Table 2.20 – Do you agree or disagree that people should be able to opt-out of receiving PAWHP? (n=152)

	Percentage (%) of respondents*
Agree	88
Disagree	5
Don't know	7

*Figures may not add to 100 per cent due to rounding.

One survey respondent commented that they felt having the option to voluntarily opt out was not enough, as those with high incomes could still receive the payment regardless of need.

"Still doesn't resolve the issue of those on high level pensions receiving it when they don't "need" it. Yes, folk can choose to opt out, but there are a lot who receive it who really don't need the help." (Survey respondent)

2.5 – Support for island communities

The Scottish Government have committed to considering how PAWHP could be improved for people who are living off-gas grid. The majority of off-gas grid households live in island or rural communities and use fuel such as oil, gas canisters or solid fuels. Living in island communities can present unique challenges for older people, especially in terms of heating their homes where being off-gas grid can often result in higher energy costs.

Costs and payment value

The survey asked respondents if there was anything that they felt would be important for the Scottish Government to consider when providing PAWHP for island communities. Many respondents highlighted the higher costs of island living, due to weather, infrastructure, and higher fuel costs for off-gas grid households.

"Rural island residents suffer colder, longer periods of cold weather, from October, various forms of heating used and additional costs, delivery being one cost on top of fuel costs. If for example buying wood, this needs to be bought months in advance of winter." (Survey respondent)

Some respondents suggested that island communities should receive a higher value payment to reflect these costs, or that the payment could be differentiated by the type of fuel that they used.

"Perhaps an additional amount is required for unique circumstances and environmental challenges." (Survey respondent)

"Island households should be eligible for higher payments proportionately to the type of fuel used for heating." (Survey respondent)

Infrastructure and housing

Some survey respondents highlighted that island communities have less robust infrastructure than those on the mainland. A few suggested that there should be additional planning in place to provide for island communities in the event of extreme weather or disruption to transport links which would prevent them from accessing fuel supplies.

"These communities that are off-grid and isolated may need more support in cases where there is a danger they are not able to access fuel due to extreme weather events. A crisis management plan should be at the ready in the local governments." (Survey respondent)

"That they are given due consideration i.e. have storage tanks, everything for their needs to be well organised in advance because their ability to travel to get services is weather dependant." (Survey respondent)

A few respondents suggested that people living on islands should be prioritised to receive payment first, as they may face colder weather earlier in the year or have to plan in advance for potential infrastructure or transport disruption when purchasing fuel.

"Where someone lives on an island the money could be given slightly earlier." (Survey respondent)

"It's a lot colder in the islands things need to be stocked up earlier as deliveries could be hampered by weather changes such as ferries stopping and unable to deliver." (Survey respondent)

One respondent suggested that providing advance notification of when the payment would be provided would allow people in island communities to plan better.

"Ensuring they know when it is to be paid so they can plan in advance." (Survey respondent)

Others noted that housing on islands is often older or in poor condition, causing difficulties with modernisation or improvements such as insulation. One respondent suggested that people living off-gas grid should be prioritised for any assistance with new heating solutions, such as heat pumps or local electricity generation.

"Considerably higher heating costs, fewer means of insulation in older properties, delivery charges for oil..." (Survey respondent)

"Make the off-grid people/rural and island communities people the first ones to get the new heating systems which are expected in the future, heat pumps/air drawn in from outside property/electricity from wind-farms supplying homes locally." (Survey respondent)

One respondent also noted that where someone who lives on an island has to travel to the mainland for medical treatment, they may have to rent an additional property and incur further heating costs. They suggested that there should be extra support in this situation, including providing payments for terminal illness in advance to help with the cost of heating an additional property.

"We have to go to the mainland for treatment and live in rented premises, then we have an extra premises to heat a sick person in. Emergency heating payments are needed also terminal illness payments are needed upfront to heat property." (Survey respondent)

Similarities with rural households

Several respondents also noted that the challenges faced by island communities were often shared by those living in rural areas, such as the costs associated with solid fuels and less established infrastructure and transport links.

"It is important to recognise that rural communities on the mainland […] can have many of the issues of island communities. Our costs using solid fuel are incredibly high. The high costs of transport (public transport is poor and expensive) means that we are at home most of the time and we have nowhere to go to (no shop, library etc.) to keep warm." (Survey respondent)

Expanded eligibility

Some survey respondents suggested that due to the circumstances of island or rural life, higher heating costs and weather conditions, there should be expanded eligibility for fuel payments for additional groups of people in these communities. Suggestions included widening eligibility to cover all households that were off-gas grid, including disabled or vulnerable households, or assessing cases on an individual basis.

"Should be offered to all [island residents] including the vulnerable/disabled, means tested. And only to those residing in Scotland." (Survey respondent)

"Rural folks need more help and don't get enough, people who are sick and disabled on Personal Independence Payment [PIP] who work really need help too. I can't breathe unless the air is a certain temperature and I have chronic pain and other conditions so have to heat my home all day and I get no help at all." (Survey respondent)

Greater consultation with island communities

Finally, one respondent suggested that there should be improved communication between the government and island communities to help tackle fuel poverty, with consultations to identify needs and raise awareness of what support is available for households.

"I think the high level of fuel poverty which clearly exists in all island communities needs to be looked at with a different approach and they should be in a different sub category as they are not just suffering in winter but in most cases all year round with prolific lack of investment by the Scottish government in insulating, use of solar panels […] and indeed appointing local staff [from the council or Scottish Government] who can liaise with locals on what they need and what would be available for them." (Survey respondent)

2.6 – Other communities and groups

Survey respondents were also asked about any unintended consequences that the proposed format for PAWHP may have on other communities and groups in Scotland. For example, people with disabilities, people of a certain sex or gender, or people who belong to a particular religion, race or ethnicity.

Most respondents chose to answer this question in terms of groups or communities that would also benefit from support with heating costs.

People with disabilities

Many respondents stated that people with disabilities can be badly affected by cold weather due to their conditions or because they have limited mobility, resulting in higher heating costs. Because of this, many respondents suggested that a fuel payment should also be provided for people with disabilities. Some suggested that this should be a universal payment, without age limits.

"People living with mental health or mobility issues who are generally in their homes date and night thus using more fuel." (Survey respondent)

"Disabled people on [Employment Support Allowance], PIP should automatically be included in the criteria regardless of age." (Survey respondent)

However, other suggestions included extending the coverage of the payment through lowering the eligible age for people with disabilities, or including people with disabilities who are unable to work. A few respondents highlighted the additional costs associated with running healthcare equipment or mobility aids (e.g. electricity costs from charging devices), which although not directly linked to heating still contribute to higher energy costs.

"People below pensionable age who have health or mobility issues but maybe can't work, should also qualify. Perhaps a payment for all vulnerable groups would be fairer and more inclusive." (Survey respondent)

"People with disability who depend on equipment for health or mobility and cannot make savings on their use as have to be on 24/7 or charged regularly to operate." (Survey respondent)

Some respondents also suggested that the payment should be extended to people with disabilities, but limited to those with certain conditions that are affected by the cold or that limit mobility.

"Disabled people and long-term debilitating medical issues, for example, cancer, renal disease, and diabetes for example where these individuals are known to feel the cold more." (Survey respondent)

"People with disabilities which limit movement, unable to counter coldness that others may use, i.e. exercise. People with incurable or life-limiting conditions may have a different experience of feeling cold or heat. Complex Regional Pain Syndrome for example." (Survey respondent)

Living situation or housing

Respondents also suggested other groups who may need additional support with heating costs during the winter period due to their living situation or type of housing. These included people living in caravans or trailers, people who are homeless or have been in prison, or those living in poorly insulated properties.

"What about the people living in permanent caravan parks?" (Survey respondent)

"Homeless applicants who have no choice but prepaid meters, people who have been in residential or in prison." (Survey respondent)

"In Scotland many people live in buildings made of stone blocks, so no cavity wall insulation for them. Also, the older tenements would need to have more insulation between floors." (Survey respondent)

2.7 – Redeterminations and appeals

Someone may ask for a redetermination regarding Pension Age Winter Heating Payment where they feel that the value of their payment has been incorrectly calculated, or they have had a change of circumstances which alters their eligibility^[4].

In line with the approach taken for Best Start Grant, Funeral Support Payment and Winter Heating Payment, the Scottish Government are proposing the following timescales for redeterminations and appeals relating to PAWHP. These are:

• Redetermination requests relating to PAWHP should be made within 31 calendar days of being notified of the determination.
• Redetermination requests can still be made up to a year after being notified of the original determination, if there is a good reason for the request being made late.
• Beginning with the day that a redetermination request is validated Social Security Scotland should have 56 calendar days to make the fresh determination.
• If there is a failure to make the redetermination within the 56 calendar day period, the individual will be informed that they have a right to appeal to the First-tier Tribunal.

Almost two thirds (63 per cent) of survey respondents agreed with the timescales proposed. However, more than a quarter (26 per cent) neither agreed nor disagreed (Table 2.21).

Table 2.21 – Do you agree or disagree with the timescales proposed for redeterminations and appeals? (n=145)

	Percentage (%) of respondents*
Agree	63
Disagree	11
Neither agree nor disagree	26

*Figures may not add to 100 per cent due to rounding.

A few respondents commented that they disagreed with the timescales for redeterminations and appeals. Some stated that the time allowed for an appeal or redetermination was too long and could leave vulnerable older people without extra financial support for heating during the winter months, when it is needed most.

"If pension age people are asking for a decision to be looked at again, it's likely that they're unable to heat their home sufficiently in the winter or anxious about being able to heat their home. The timescales for redeterminations push the decision too far into winter - leaving vulnerable pensioners in cold homes." (Survey respondent)

However, one respondent stated that longer timescales to apply for a redetermination or appeal should be allowed where someone was having to deal with difficult circumstances, such as caring for a terminally ill person.

"When you are with your terminally ill person living in hospice/hospital all [this information] is the last thing you want to look at. Grief knocks all sense of time. Extra-long time needed to appeal in cases of attending to the seriously ill or death." (Survey respondent)