The Carer Assistance (Carer Support Payment) Amendment Regulations 2024: scrutiny report

The Scottish Commission on Social Security's scrutiny report on the draft Carer Assistance (Carer Support Payment) Amendment Regulations 2024

Exceptions for carers aged 16-19 in non-advanced education

The draft regulations bring forward commencement of the extension of eligibility currently within the regulations to a further group of students aged 16 to 19 with certain exceptional circumstances (e.g. who do not have access to support from parents or guardians). As noted in our scrutiny report on the principal regulations, SCoSS welcomes the widening of access to students who will now be able to access CSP when they would previously have faced a choice of either accessing Carer’s Allowance or taking up opportunities for full-time study.

We note draft regulation 2(2) brings this change forward to 24 June 2024, rather than October 2024 as previously stated. We welcome this change and agree with the view expressed by stakeholders that the circumstances of student carers can differ from other students in that they are often unable to take on employment opportunities outside of term time.

“A lot of student support ceases over the summer months and we hear from unpaid carers that many services for their cared-for person also reduces over this period, resulting in many unpaid carers taking on more intensive caring roles over the summer months… employment opportunities may not be possible for them.” Carers Trust Scotland1Carers Trust Scotland response to SCoSS call for evidence, March 2024

The Scottish Funding Council noted, in evidence to SCoSS, that caring is “disproportionately experienced by young people living in communities with higher levels of deprivation, and in households with lower incomes.”2 Scottish Funding Council response to SCoSS call for evidence, March 2024 We would anticipate, therefore, that the extra financial support for this group from Summer 2024 will be well received and welcome this change of approach and its contribution towards achieving social security principle e.3Social Security (Scotland) Act 2018, Part 1, 1 (e) “the Scottish social security system is to contribute to reducing poverty in Scotland”

Two of the exceptional circumstances where 16 to 19-year-olds are eligible for CSP refer to couples where a) the claimant’s partner is not a student, and b) where the claimant’s partner is a student but one of the other exceptions applies to that partner. Carers Trust Scotland noted that how this is communicated can be confusing, e.g. when it is not spelled out that the exception only applies to couples who live together. Further consideration could be given to how the exceptions are communicated with carers as part of the Scottish Government’s communication plans.

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