The Welfare Foods (Best Start Foods) (Scotland) Amendment Regulations 2024: scrutiny report

Observation 1: In the longer term, consideration could be given to aligning both language and processes with the wider Scottish social security system.

Observation 2: SCoSS welcomes the proposed removal of the income thresholds that apply to qualifying benefits for Best Start Foods, which will extend eligibility to previously excluded low-income groups and has potential to improve take-up and efficiency by simplifying eligibility criteria.

Observation 3: SCoSS welcomes the introduction of advance applications for Best Start Foods and of provision for backdated awards of qualifying benefits to confer eligibility for Best Start Foods.

Observation 4: SCoSS welcomes the extension of the eight-week ‘run-on’ for Best Start Foods awards to qualifying benefits other than Universal Credit.

Observation 5: SCoSS broadly welcomes the changes being made to the rules for eligibility for Best Start Foods, acknowledges the challenge of communicating complex eligibility criteria and notes the importance of clear and unambiguous guidance documentation for applicants, administrators etc.

Observation 6: SCoSS welcomes the prioritisation of Best Start Foods applications from the pregnant person themself during pregnancy where there are competing claims from eligible applicants, and the commitment to introduce further provisions for adjudicating between competing claims.

Recommendation 1: As part of the continuing updating of the relevant impact assessments, the Scottish Government should work with stakeholders, including those engaged in supporting individuals experiencing domestic or financial abuse, to develop an understanding of the potential for abuse by a partner and what additional mitigations may need to be put in place.

Recommendation 2: The Scottish Government should publish clear, accessible guidance on who is likely to be able to receive an alternative form of payment of Best Start Foods, the process for requesting one and how to challenge decisions. Individuals who receive a pre-paid card should receive guidance on the type of retailers who can accept the card and how to request the addition of their local retailer to the list of approved retailers.

Observation 7: The Scottish Government should continue to consider the case for payment of Best Start Foods by bank credit as the default, with a view to ensuring the scheme respects individuals’ dignity as much as possible, without putting at risk the eligibility of those with no recourse to public funds.