Social Security (Up-rating) (Miscellaneous Amendments) (Scotland) Regulations 2022: scrutiny report
The Scottish Commission on Social Security's scrutiny report on the draft Social Security (Up-rating) (Miscellaneous Amendments) (Scotland) Regulations 2022 with recommendations for the Scottish Government.
- Document Cover
- Summary of recommendations and observations
- Executive Summary
- Scottish Child Payment
- Best Start
- Child Winter Heating Assistance (CWHA)
- Coronavirus Carer’s Allowance Supplement (CCAS)
- Annex A: Overview – powers and constraints
- Annex B: Summary of key provisions in the draft
- Annex C: Scrutiny timeline
Child Winter Heating Assistance (CWHA)
CWHA provides children, young people and their families with an annual winter payment to assist them in financially mitigating the increased costs they incur in heating their homes as a result of having a disability or long-term condition.
SCoSS welcomes that CWHA is to be increased by 5%, 1.9% over the CPI rate of 3.1%. The evidence in support of this additional measure is set out in the section 86A report. This highlights how “…the energy sector has contributed to the inflationary pressures after [the] Office of Gas and Electricity Markets’ (Ofgem) 9% increase of the tariff cap in April 2021”. This has resulted in domestic gas bills rising by 28.1% and electricity by 18.8%.
What the section 86A report does not explicitly draw attention to is the case for this additional increase on equalities grounds (principle gii becomes relevant here). As disabled people disproportionately have additional heating needs and hence extra heating costs, high inflation in energy costs will disproportionately impact on them. Households with a disabled family member are disproportionately likely to experience fuel poverty. This is an example of where an equalities impact perspective can be helpful.
The inflation rate for such costs thus vastly exceeds the CPI September figure of 3.1%, and there is currently no sign that inflation will not continue to rise. In fact, while the increase to 5% is certainly welcome, it is possible it will still fall short of maintaining value and hence its contribution to reducing poverty. It is not clear what financial modelling and constraints, including affordability, gave rise to the decision to increase by 5%, though these may well exist. Ultimately such decisions come down to Ministerial judgement.
Observation 4: SCoSS welcomes the uprating of CWHA, given that additional heating costs are something that many disabled people experience, and the extent to which disabled people (and children) are disproportionately likely to suffer from poverty.