Young Carer Grant regulations: consultation analysis

Discussion

The consultation was successful in engaging a wide range of key partners in discussion of all the areas covered by the guidance. Responses were provided by individuals (including young carers themselves and/or parents of young carers), public sector organisations, and third sector organisations responsible for either information provision and/or directly supporting/representing young carers. As well as detailed feedback being provided for all sections of the consultation, respondents also provided additional comments and/or suggested changes to assist in finalising the regulations.

Main Findings

There was overwhelming support for the introduction of a Young Carer Grant, and general support for all elements of the Young Carer Grant as proposed in the consultation document. Most respondents felt that the draft regulations would be likely to meet the stated policy aims, agreed that annual applications would be sensible, agreed with the timescales proposed for the re-determination process, and most had no comments on the proposed residency requirements.

There was unanimous agreement that young carers should be allowed to combine hours caring for more than one person to meet the required 16 hours average each week, and that young carers should be eligible for the Young Carer Grant when another carer is in receipt of Carer's Allowance for providing care for the same person. Indeed, it was also considered important to allow multiple applications from young carers who are providing care for the same person.

Most respondents were unable to identify any additional equality impacts of the Young Carer Grant, or any impacts of the Young Carer Grant on children's rights and wellbeing and/or business related impacts. There were, however, some common concerns that were discussed across the consultation.

Limitations of the Definition

The definition of a young carer was considered by many to be too restrictive raising concerns that many vulnerable young carers would be excluded from the grant. In particular, it was suggested that, by not recognising social, mental health and emotional support within the caring definition this would be likely to exclude many who care for those with mental health issues and/or addictions. It was also suggested that this limitation could have a potential impact on young carers that provide supervisory care to keep a cared-for person safe, and/or provide care to siblings (who do not have a disability) as a result of the main care giver being the cared-for person.

Further, many suggested that requiring the cared-for person to be in receipt of certain benefits would again be likely to exclude some young carers, either because the cared-for person is not eligible for/does not claim benefits (again seen to impact most on those caring for people with mental health issues and/or addictions) or because their benefits have been stopped for any reason.

Age and Educational Status

The proposed age for eligibility, i.e. aged 16-17 (and 18 if still at school), also generated significant discussion among respondents. Many felt this age range was too limited. It was suggested that all those aged 18 should be eligible for the Young Carer Grant, regardless of their educational status. It was noted that those aged 18 who attend college or university (often because this offers more flexibility to combine with their caring responsibilities compared to school) are not eligible for the Carer's Allowance either and therefore would not receive any financial support at this important transitionary time. It was generally considered unfair for those aged 18 to only qualify for the grant if they were still at school.

It was also noted several times throughout the consultation that the requirement for young carers to be at school was also likely to result in those who have opted for less traditional forms of education, such as home education, to be excluded from the grant. Again, this was considered unfair and not in keeping with the general ethos of the grant.

Many respondents suggested that the requirement to be at school should be dropped so that those attending any form of full- or part-time education, those completing an apprenticeship, those that are in employment and/or who are unemployed should all be eligible.

It was also suggested that the age range needed to be extended. Many felt it needed to include all 18 year olds, while others suggested that the upper age limit should be increased to 20 in order to better reflect 'young people', and yet others suggested that 'young adults' should be eligible with the age limit being increased to 25 to accommodate this.

Annual Applications

While many were in favour of the need for annual applications, both those who supported this proposal and those who were against it suggested that any need to re-apply should be accompanied by reminder correspondence (either an opt-in reminder or an automatic reminder for all existing claimants). It was felt that this would be necessary to maximise continued up-take.

Some also suggested that any re-application should be simpler than the initial application process. It was felt that the form could be pre-populated and sent to claimants to check and confirm/correct the necessary information. The process needed to be made as simple as possible for potential applicants, it was felt.

Multiple Carers

One of the areas where there was unanimous support was the need to allow multiple applications from carers who are caring for the same cared-for person. This included allowing a Young Carer Grant application where someone else is already in receipt of Carer's Allowance, but also to allow for multiple young carers within one household/per cared-for person. It was considered that caring responsibilities are often split between different carers and it was considered unfair to place the situation/needs of one carer ahead of another. It was generally felt that, as long as the young carer is providing the required average of 16 hours of care per week, then they should be entitled to the grant.

Re-Determination

While there was general support for the timescales proposed for the re-determination period, some respondents suggested that either the timescale for an applicant to request a re-determination should be extended and/or that there needed to be flexibility built into this. It was suggested there may be legitimate circumstances where a young carer may find it difficult to request a re-determination within 31 calendar days, for example, where they need to access support to complete the process, where additional information/evidence is required (and which cannot be provided within the timescale), or where either the young carer or cared-for person is ill/hospitalised during this period. It was felt it would be unfair to penalise young carers in such situations and, therefore, greater flexibility/discretion was required around this timescale.

Next Steps

The responses to the consultation, along with the summary provided in this report, will be considered ahead of any final policy decisions being made. The draft regulations will then follow a form of 'super-affirmative' procedure, as explained in the Social Security (Scotland) Act^[3]. They will be scrutinised by the independent Scottish Commission on Social Security, revised as needed following the Commission's report and laid in draft for approval by the Scottish Parliament. They will then need to complete the parliamentary process as an 'affirmative instrument' before payment of the Young Carer Grant can take place^[4].

The Young Carer Grant service design team within the Scottish Government has started to plan the business processes which will allow young carers to access and receive the Young Carer Grant. This includes the application process. The Scottish Government are taking an 'agile' approach to service design, which means that they will continually test evolving designs with stakeholders to make the client journey as user-friendly as possible. When approved, the Young Carer Grant will be delivered by Social Security Scotland (the new Executive Agency of the Scottish Government).

Conclusion

The consultation shows that, while there is general support for the creation of the Young Carer Grant, and for the draft regulations as presented, some key areas of concern remain which may be worthy of further consideration before finalising arrangements for the Young Carer Grant. In particular, concerns regarding potential groups of young carers who would be excluded from this support (based on the current draft regulations), are linked to perceptions that the Young Carer Grant may be limited in helping improve young carers' health and education outcomes at a key transition period in their lives. Further consideration of the eligibility criteria may allow for the grant to be more impactful and provide recognition and support to a wider range of vulnerable young people.