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The Carer’s Assistance (Young Carer Grant and Carer Support Payment) (Miscellaneous Amendment and Saving Provision) (Scotland) Regulations 2025: scrutiny report

The Scottish Commission on Social Security's scrutiny report on the draft Carer’s Assistance (Young Carer Grant and Carer Support Payment) (Miscellaneous Amendment and Saving Provision) (Scotland) Regulations 2025

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Contents

4. Single benefit with three components

Carer Additional Person Payment and Scottish Carer Supplement are not standalone benefits. They are dependent on the carer getting Carer Support Payment. The structure chosen to deliver them is through creating a single benefit which is made up of three components: Carer Support Payment, Scottish Carer Supplement and Carer Additional Person Payment. The single benefit is called ‘Carer Support’.

The Scottish Government chose this three-in-one structure rather than separate benefits as the only deliverable option to allow for the various income disregards and passports to additional elements in Universal Credit and Pension Credit and other interactions with benefits reserved to the UK Parliament. They also consider that this structure allows the application process to be as simple as possible and for a single redetermination and appeals process to be straightforward.¹

With multiple and complex interactions with UK and other Scottish benefits and systems it is crucial to prioritise getting this right. Carers rely on these systems working well. When they go wrong, carers miss out on entitlements or find themselves repaying overpaid benefit.

However, this approach presents challenges that make it difficult to meet some charter expectations. Below, we comment on issues related to take-up, applications and providing choices to carers when only a single award is available.

4.1 Take-up and communication

It is not known at present how many carers may be missing out on benefit entitlement. The Scottish Government’s take-up strategy describes the fundamental challenge of identifying carers who may not have self-identified as such.² They are considering the best way to estimate take-up rates for Carer Support Payment following the completion of case transfer from Carer’s Allowance. However, it is possible that many carers are missing out. For Carer’s Allowance, a DWP study in 2010 estimated take-up to be only around 65 per cent.³

Benefit take-up is influenced by factors such as whether people have heard of a benefit, whether they think they are eligible, how complex it is to apply and whether the amount of benefit is worth the stress and effort of applying for it.⁴

The changes to payments for carers come with a set of new terms, adding to the already complex landscape. There is Carer Support, the umbrella term for Carer Support Payment, Scottish Carer Supplement and Carer Additional Person Payment, there is Young Carer Grant and there is also in the reserved system, Universal Credit carer element and Pension Credit carer addition and, for some, Carer’s Allowance. With so many similarly named benefits, making sure that carers are all made aware of what is available to them, and crucially, in a way that they understand whether they are eligible, is likely to require a new and sustained response from the Scottish Government. An additional challenge is reaching those caring for more than one person. Having multiple caring roles can be extremely demanding in effort and time, especially if the people being cared for have very different needs.⁵

Recommendation 4: With new social security support for carers creating a more complex landscape, the Scottish Government should develop a tailored and sustained communications and take-up plan to ensure all carers, particularly those with multiple caring roles, are aware of the support they are entitled to.

We heard from stakeholders that the umbrella term, ‘Carer Support’, chosen to represent the three payments could be confusing for carers who may assume it is practical support rather than financial. The Scottish Government has said that, after testing the approach with user research participants, they intend in practice to set out the three components separately when communicating with people and do not intend to use the umbrella term unless it is necessary to aid understanding of entitlement, redetermination and appeals.

Given that the umbrella term will be used in some situations, it would be wise to test the term ‘Carer Support’ alongside the alternative, ‘Carer Payments’, which the Scottish Government told us that they consider an equally valid option.⁶

Recommendation 5: The Scottish Government should test with carers the alternative umbrella terms, ‘Carer Support’ and ‘Carer Payments’, to ensure the term chosen is not a barrier to take up.

We heard from stakeholders that some groups may be more likely to miss out, such as carers who have communication needs or do not speak English as their first language. The Scottish Government report, Research into seldom-heard groups within the Scottish social security system,⁷ noted that, alongside the groups identified in the Scottish Government 2019 Seldom Heard Voices research programme, additional groups may have low rates of benefit take-up. These include:

People from established minority ethnic communities who are at risk of marginalisation due to prejudice, language barriers and cultural differences.
People with long-term physical and mental health impairments or conditions, including fluctuating and/or less visible conditions.
People with learning disabilities and learning difficulties.
Socially isolated older adults.

The report suggests that a strategy to overcome barriers could include ‘targeted and culturally responsive awareness raising, and the provision of accessible, accurate and timely information’.

Social Security Scotland offers factsheets in 12 community languages and encourages their use in community settings such as GP surgeries and libraries. We encourage the Scottish Government as they consider findings from the seldom-heard groups research to look at providing more information directly to carers in accessible formats and multiple languages.

Recommendation 6: The Scottish Government should provide more information on social security entitlements for carers in accessible formats and multiple languages to ensure carers with communication needs or limited English do not miss out.

4.2 Applying for Carer Additional Person Payment

The way to apply for Carer Additional Person Payment will depend on whether a carer wishes to add it to an existing award of Carer Support Payment or is making a completely new application for Carer Support.

For new claimants, the online application process will include an eligibility checker and will outline the three components available through ‘Carer Support’. This is intended to “support carers in understanding the purpose of each component”.⁸

Carers already getting Carer Support Payment will apply for Carer Additional Person Payment by informing Social Security Scotland about the additional people they care for. This will be done by reporting a change in circumstances even if they have been caring for the additional person for some time.

Designing this part of the client journey will require some care to make sure that names of forms, for example, do not inadvertently present a barrier to carers understanding that they are eligible and, therefore, potentially reducing take up. A standard ‘change of circumstances’ form may not be appropriate. A tailored form could be used while still routing the request through the legal route of determination without application.

Recommendation 7: To avoid creating unintended barriers to take up, rather than relying on the standard change of circumstances process the Scottish Government should design with carers a specific way for them to request that Carer Additional Person Payment is added to their award.

4.3 Choice of components

For a new application for Carer Support, the 2018 Act and regulations require Social Security Scotland to determine entitlement to all three components. However, a carer may be eligible for Carer Additional Person Payment but not wish to claim it, for example, because the household will be better off if another family member applies instead. In this case, there seems to be no clear legal route for Social Security Scotland not to award Carer Additional Person Payment if they know the applicant is eligible.

In practice, the application form may give a carer the option of not asking for Carer Additional Person Payment. This would allow Social Security Scotland to determine the award without Carer Additional Person Payment based on the available evidence. However, if a carer inadvertently gave information about additional care or later changed their mind, there would appear to be no provision in the 2018 Act for them to withdraw Carer Additional Person Payment component from their application or, once an award has been made, to end only this component.⁹

The same question of choice could arise on redetermination and appeal. We understand that when a redetermination or appeal is requested for a particular component, all three components will be considered.

Recommendation 8: To give carers more choice about the support they receive, the Scottish Government should ensure regulations and processes allow carers applying for Carer Support to choose not to claim Carer Additional Person Payment. Carers should also be able to withdraw Carer Additional Person Payment from an application or end entitlement to this component without ending the whole award.