The Carer’s Assistance (Carer Support Payment) (Scotland) Regulations 2023: scrutiny report
The Scottish Commission on Social Security's scrutiny report on the draft Carer’s Assistance (Carer Support Payment) (Scotland) Regulations 2023
Contents
- Document Cover
- Summary of recommendations and observations
- Executive summary
- 1. Introduction
- 2. Aims of Carer Support Payment
- 3. Policy changes from Carer’s Allowance
- 4. Employment and earnings
- 5. Carer’s Allowance Supplement
- 6. Older carers
- 7. Future Changes
- 8. Regulations: areas for clarification
- 9. Approach to scrutiny
- Annexe A: External stakeholders
- Annexe B: Scrutiny timeline
- Annexe C: About the Scottish Commission on Social Security
2. Aims of Carer Support Payment
CA was intended to be an earnings-replacement benefit for those who had given up work to provide care.1P19-20 House of Commons (1974) Report on Social Security Provision for Chronically Sick and Disabled Persons. (1973-74, HC 276) However, it is often misunderstood among carers as a payment in recognition of their caring role.2National Audit Office (2009) Supporting Carers to Care (www.nao.org.uk); Berthoud, R. (2010) The take-up of Carer’s Allowance: A feasibility study DWP WP 84 Consequently, the purpose of CA is ambiguous and the policy objective unclear.38 Fry, G. et al (2011) Developing a clearer understanding of the Carer’s Allowance claimant group, DWP research report 739.; Berthoud, R. (2010) The take-up of Carer’s Allowance: A feasibility study DWP WP 84
The aims of CSP are:
- Aim 1: Carer Support Payment provides income for unpaid carers in recognition of their vital role and its impact on their lives. It is delivered in a way that takes into account that different carers have different needs, and that different caring situations have different impacts
- Aim 2: Carer Support Payment provides stability and supports carers to access opportunities outside of caring, where possible, and they wish to do so
- Aim 3: Carer Support Payment is designed to ensure carers have a positive experience of the social security system, and to maximise carers’ take-up of all support available to them.4 Carer Support Payment: Fairer Scotland Duty Assessment
The aims of CSP are wider than the earnings-replacement aims of CA. For example, CSP emphasises the contribution towards recognising unpaid carers’ vital role, their life experiences beyond caring and their experience of the system.
Most respondents to the Scottish Government’s public consultation supported the aim that CSP would not be a ‘payment for care [but] provide some financial support and recognition for those who choose to, or who have had to give up or limit their employment or study because of caring responsibilities’.5https://www.gov.scot/publications/analysis-written-responses-consultation-social-security-scotland/ Analysis of written responses to the consultation on social security in Scotland
One of the lessons from CA is that objectives can be misunderstood and mis-communicated, leading to confusion, lack of recognition and poor take up. By developing new aims through consulting with carers and the organisations that support them, and by stating the aims of CSP clearly from the start, the Scottish Government has taken this lesson on board. This is a good foundation for ongoing communication with carers that makes it clear which aspects of CSP and the way it is delivered are meeting these new objectives.
Including recognition of the caring role as an aim of CSP has implications for the design of the benefit, particularly in how it will recognise the role of older carers, many of whom will be entitled to CSP but will not be paid because of overlapping benefits rules (see section 6.1). The Scottish Government is considering future changes to CSP intended to provide more recognition to older carers and others with long-term caring roles.
To fulfil the aims of supporting carers to access opportunities outside caring, and to maximise take up of all support available to them, the social security system will need to make improved connections with wider support for carers. The Government has proposed further work to ensure carers have information and advice on support available to them, including in the longer term to link carers to other services at key moments of transition, such as the start or end of a caring role.6Scottish Carer’s Assistance consultation: https://www.gov.scot/publications/social-security-scottish-carers-assistance-consultation-scottish-government-response/documents/ Monitoring how this work impacts on carers take up of wider opportunities and support should also be undertaken.
The development of CSP offers the Scottish Government an opportunity to consider the roles of both social security and social care in supporting carers’ outcomes. The availability of social care can have a direct bearing on whether people undertake unpaid care, and, in turn, support from unpaid carers can also reduce the amount of social care provided.7Disability and Carer Benefits Expert Advisory Group: https://www.gov.scot/publications/disability-and-carer-benefits-expert-advisory-group-letter-to-cabinet-secretary-for-social-security-and-older-people-on-scottish-carers-assistance/ Unpaid carers should not be expected to take on or maintain a caring role they have not chosen due to inadequacies in social care.8Disability and Carer Benefits Expert Advisory Group: https://www.swbg.org.uk/content/publications/Towards-a-transformative-universal-adult-social-care-support-service-for-Scotland.pdf An emphasis on recognising the value of caring, gives CSP a role in contributing towards meeting the National Carer’s Strategy strategic outcome of recognising caring, which is also reflected in local and national policy-making.9P41: https://www.gov.scot/publications/national-carers-strategy/pages/6/ Furthermore, there is an opportunity to develop the strategy further by aligning the relationship between carer benefits and social care towards achieving high-level desired outcomes for carers.
Recommendation 1: Carer Support Payment aims to recognise the vital caring role provided by unpaid carers which was not a stated aim of Carer’s Allowance. The Scottish Government should work with carers and stakeholders to understand what changes to Carer Support Payment would provide that recognition and how wider carer support and services could be better joined up with social security.
Recommendation 2: Carer Support Payment’s aims should be reinforced in communications with carers in order that they remain clear and unambiguous.