Draft Winter Heating Assistance (Low Income) (Scotland) Regulations 2022: scrutiny report
The Scottish Commission on Social Security's scrutiny report on the draft Winter Heating Assistance (Low Income) (Scotland) Regulations 2022
2. Impact Assessments
Impact assessments were not shared with SCoSS alongside the publication of the draft Regulations. At an advanced stage in the preparation of our scrutiny report, SCoSS received draft impact assessments with some limitations placed on our ability to make reference to them.
SCoSS notes the significant equalities and rural/remote impacts of LIWHA. It targets support towards people on low incomes who are of pension age, disabled or families who have responsibility for either a child under the age of 5 or a disabled child, all of which are protected characteristics under the Equality Act 2010. The impact of the introduction of LIWHA will vary considerably according to geography.
Any payment intended to help with energy costs is likely to go further in a city than in a remote, ‘off-grid’ community. People outside the Scottish Highlands seldom received a CWP and may receive support with winter energy costs for the first time through LIWHA, while those in some parts of the Highlands may get less support than in the past.
Therefore, social security principles, notably principle (e) of the Scottish social security system principles is to contribute to reducing poverty in Scotland and principle (g) (ii); opportunities are to be sought to continuously improve the Scottish social security system in ways which advance equality and non-discrimination, deserve adequate consideration as part of the policy development process.
The purpose of impact assessments is to inform policy development in order to help prevent inequalities from inadvertently arising. They should, therefore, always be undertaken while policy is still under development so that the particular concerns related to groups affected by the policy can be assessed and addressed where possible.
These should be shared with SCoSS for its consideration alongside all Regulations in order to inform our scrutiny of Regulations.
Recommendation 1: Impact assessments should be produced while policy is under development and sent to SCoSS alongside draft Regulations.