Section 3. Changes to Carer Support Payment
When Carer Support Payment is first launched, we plan to keep many of the eligibility criteria the same as Carer’s Allowance. We recognise that this will not immediately achieve all of the aims we have for carers. This is to make sure we don’t create a ‘two-tier system’ where carers already getting Carer’s Allowance are treated differently from people who have newly applied for Carer Support Payment. This approach also helps to achieve a safe and secure transition, ensuring that throughout the extensive and complex task of transferring carers’ benefits from the Department for Work and Pensions to Social Security Scotland, they continue to receive the right money, at the right time.
The consultation set out the priority changes that we want to make to the current Carer’s Allowance rules, including increasing access to education, recognising different caring situations, providing more stability of support where payments are affected by life events, and addressing barriers to taking on, or staying in, paid work. We also proposed to explore support for those carers who have a long-term caring role, for example those who have looked after a disabled child for the majority of their lives. We recognise that such long-term roles can have particular impacts, not only financially, but also on opportunities to participate in learning, leisure and social engagement.
A recurring theme from the consultation responses was for changes to go further and be made faster. However, we are aware of the need to balance any changes we would need to make, against the funding to invest in making those changes. We will need to decide how affordable and sustainable any improvements we wish to make are, as part of the fixed Scottish budget, and we need to make sure that changes are targeted where they will deliver the most benefit. We also know how important it is that any improvements we make don’t do anything which would risk the other financial support carers get from reserved benefits, and we have dependencies on other government agencies such as the Department of Work and Pensions and His Majesty’s Revenue and Customs, as well as external organisations, which can affect when we are able to make changes.
However from launch we are committed to allowing many carers to study full-time and receive Carer Support Payment by reducing the education restriction. We also intend to increase the run on of payments from eight to twelve weeks after a cared for person dies, as soon as practicable after case transfer is complete.
Access to education and training
In the consultation we proposed removing the current Carer’s Allowance education restriction to increase access to Carer Support Payment for full-time students as we know this can be a barrier to education and that this may be a problem for student carers in particular, who are less able to support themselves through paid work.
The majority of respondents (97%) agreed with this proposal and noted that the current rules constituted a barrier to education, and that this change would address this, particularly if Carer Support Payment were paid alongside existing grants or bursaries. Respondents highlighted that this was a long-term investment in carers, improving career options and earning potential for when their caring role stops.
The only negative comments concerned the issue of fitting in full-time study with full-time caring, with some suggestions that safeguards should be put in place to avoid detrimental impacts on carers’ health and wellbeing. However, others noted that many courses were now flexible and delivered online or in a hybrid fashion, thereby making it feasible for carers to study alongside caring.
Scottish Government response
As the majority of consultation responses strongly agree with this proposal, we intend to extend entitlement to those in full-time, further and higher education from launch of Carer Support Payment. Although this was part of our plans for future improvements, we have listened to carers, who told us in the consultation that they wanted to see changes sooner. This would mean that more student carers could receive Carer Support Payment, compared to the current Carer’s Allowance system, as soon as we launch the benefit later this year. This will mostly help young carers, and in particular, women who most typically take on caring roles and make up the majority of carers. Women already face a gender pay gap and are more likely to have been affected by previous benefit changes. This is a huge milestone for our new benefit and for those who wish to study alongside their caring role, allowing them to improve their qualifications and skills and for a life of their own, outside of caring. We are working closely with the Student Awards Agency Scotland and the Scottish Funding Council to ensure that the extension of entitlement to Carer Support Payment is fully reflected within relevant guidance and that overall levels of support for full-time student carers across social security and further and higher education are maintained.
We are continuing to consider the position for student carers who study non-advanced educational courses. Many young carers aged 16 to 19 in non-advanced education will be able to receive support through the Young Carer Grant and the Education Maintenance Allowance. Their parents or guardians should also continue to have access to support through reserved benefits such as Child Benefit, Universal Credit and Child Tax Credit. In line with our policies on the Young Carer Grant, it is important to get the balance right between providing support but not incentivising or normalising young people taking on a substantive caring role alongside their school-level education. We will continue to look carefully at this and the interaction between Carer Support Payment and the Young Carer Grant, and how they interact with wider support in the education and reserved benefits systems, to ensure we continue to get this balance right and to address any gaps in entitlement.
In order to maximise benefit uptake, we will work with stakeholders, as well as carer organisations to identify the best ways to communicate this new entitlement and to ensure that student carers have access to information and advice when we launch this new policy. We also want to consider how we link carers to wider services on things like education, work and volunteering opportunities and to provide advice at particular points of transition, for instance at the beginning or end of a caring role.
Recognising different caring situations
Carer’s Allowance is paid where 35 hours or more of care is provided each week by one person, for one person, in receipt of a certain disability benefit. This means that where someone is caring for 35 hours or more per week, but this care is split across two or more people, they aren’t eligible to get the benefit. It also means that where two people are each caring for 35 hours or more for the same person, only one Carer’s Allowance payment is made. We recognise that this may feel unfair, where the impact on the carer may be the same, regardless of the number of people who the caring is shared across, or the number of carers providing the care for the cared for person.
We are already committed to providing extra support for those caring for more than one person, where they have two significant caring roles, through the Carer’s Additional Person Payment. However we also considered the option to allow carers to add together hours spent caring for two different people to meet the 35 hours per week caring requirement.
There wouldn’t be any rules on the number of hours a carer would need to be caring for each person, as long as it added up to 35 hours overall, and both cared for persons were receiving a qualifying disability benefit.
A large majority of respondents agreed with the proposal (79%). Respondents were positive about how this approach would better recognise different caring situations.
There were some concerns regarding administrative complications. These included the need to deal with multiple applications, providing and processing additional changes of circumstances, and difficulties for carers combining and counting hours of care.
A small number of respondents voiced concerns about impacts on reserved benefits of the cared for people who could lose their Severe Disability Premium, and a very small number of respondents were worried that there could be a rise in fraudulent claims and abuse of the system.
A few respondents asked that consideration be given to providing different levels of payment according to the amount of hours provided, or according to the number of people cared for.
Scottish Government response
We welcome that the majority (79%) of respondents agree with this approach and will continue to explore the option of allowing caring hours to be added together to meet the 35 hour eligibility criteria in future.
We recognise the complexity of this proposal for carers and the points made regarding the effects on reserved benefits (as this proposal could affect the reserved benefits for two people rather than one, as is currently). We do, however, aim to better recognise different caring circumstances, including more intense caring roles through Carer’s Additional Person Payment.
We will use the consultation responses to inform our on-going consideration of the option to allow carers to add together caring hours across two cared for people. Final policy decisions and timings on this will be confirmed at a later date.
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