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
Summary of recommendations and observations
Observation 1: It may be worth considering whether there might be a case to explicitly reposition these annual regulations as an opportunity to make minor, straightforward adjustments of various kinds.
Observation 2: SCoSS notes that what constitutes maintenance or improvement in support for an adequate standard of living and contribution towards reducing poverty is affected by factors other than uprating in line with September CPI or additional increases. These include external events that increase or create new needs and hence income needs, changes to one form of provision that offset increases or reductions in another, and different inflation rates within the basket of goods comprising CPI, and these may impact disproportionately on particular equality groups.
Observation 3: SCoSS notes that the less stable the environment and the more that regulations go beyond uprating in line with CPI the stronger the case is likely to be for stakeholder engagement and additional supporting data, including financial modelling and assessment of the impact on equality groups.
Recommendation 1: In view of the rapid and substantial rise in inflation since September 2021, and the possibility that by April 2022 a 3.1% increase could fall well short of CPI, we invite the Scottish Government to set out its thoughts on the need for mitigating action and its strategic approach to adjustments in light of inflation volatility.
Recommendation 2: The Scottish Government is requested to clarify if they intend to double or uprate the Scottish Child Payment bridging payment for children over 6 years.
Recommendation 3: SCoSS invites the Scottish Government to clarify whether the increase in income threshold for Best Start Foods takes account of the increase in the National Living Wage and confirm that eligibility has not been inadvertently tightened.
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.
Recommendation 4: In view of the impact of the pandemic on unpaid carers, SCoSS invites the Scottish Government to set out its thoughts on the case for continuing to pay the Coronavirus Carers Allowance Supplement beyond 31 March 2022.