Social Justice and Social Security Committee

Meeting date: Thursday, September 21, 2023

Official Report 636KB pdf

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Decision on Taking Business in Private

Good morning, and welcome to the 21st meeting in 2023 of the Social Justice and Social Security Committee. We have no apologies for today’s meeting. Our first item of business is a decision on whether to take agenda items 4, 5 and 6 in private. Do we agree to do so?

Members indicated agreement.

Thank you.

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Carer’s Assistance (Carer Support Payment) (Scotland) Regulations 2023 [Draft]

Our next item is an evidence session on draft regulations. The carer support payment will replace the carers allowance in Scotland. Next week, we will hear from the Cabinet Secretary for Social Justice on the regulations. I refer members to papers 1 and 2.

I welcome to the meeting Fiona Collie, the head of policy and public affairs, Scotland and Northern Ireland, Carers Scotland, who is joining us in the room. I also welcome Maggie Chiwanza, chief executive of the Minority Ethnic Carers of People Project; Judith Paterson, the interim co-chair of the Scottish Commission on Social Security; and Paul Traynor, the head of the Scottish young carers services alliance, Carers Trust Scotland. They are all joining us remotely. Good morning, and thank you all for accepting our invitation.

Before we proceed with our questions, there are a few things to point out about the format of the meeting. Please wait until I say your name, or the member asking the question does, before speaking. Do not feel that you have to answer every question, and if you have nothing new to add to what is said by others, that is perfectly okay. Members and witnesses online, please allow our broadcasting colleagues a few seconds to turn on your microphone before you start to speak. You can indicate with an R in the chat box on Zoom that you wish to come in on a question. I ask everyone to keep questions and answers as concise as possible.

I now invite members to ask questions in turn.

Good morning. Thank you all very much for coming along. I will start by asking Fiona Collie and Paul Traynor a question, which picks up on something in your submissions. Carers Trust Scotland and Carers Scotland do not accept the Scottish Government’s argument that extending payments might incentivise young carers to take on a larger caring role. Fiona, perhaps I can start with you and ask, why not?

First, there is no evidence that that will be the case, but we also need to meet young carers where they are. We know that young carers have significant levels of care and responsibility, and there seems to be no good reason not to support them. When I looked at some of the information around the young carer grant, for example, the numbers claiming it are relatively low. It is based on 16 hours a week, and only a certain percentage of young carers will even meet the threshold for the new carer support payment, which is 35 hours.

In a household in which a young carer lives, there may be an adult carer as well who is claiming carers allowance. Fundamentally, however, young carers are already providing significant levels of support, and, at the moment, the proposals indicate that we would not provide financial support alongside that.

Thank you. Paul Traynor, do you want to add anything to what you put in your submission?

I just want to echo what Fiona Collie said. It is unclear what the Scottish Government’s evidence is for its taking the position that the carer support payment to those aged 16 to 19 in full-time non-advanced education would incentivise young carers. We would like to see a wee bit more information on how that decision was reached.

In 2022, from our young carer research, we found that 14 per cent of young carers were providing 50-plus hours of care a week and that around 36 per cent were providing between 20 and 49 hours a week, so it is not really about incentivising. It is about recognition that young carers are already undertaking significant caring roles, and they should be entitled to support as a result of that. Young carers are already undertaking significant roles, and they are reporting that that is a key issue for them.

I do not know whether the other witnesses want to add anything at this point. I will take the silence as a no.

The other point that all the witnesses argue is that the proposed rules on education create unnecessary complexity. What might be the impact of that increased complexity? I do not know whether Maggie Chiwanza or Paul Traynor wants to start on that one. Paul, do you want to go first?

I am happy to speak on that one. Our view is that the rule of excluding only those who are aged 16 to 19 and are in full-time, non-advanced education creates a lot of complexity. As the rules for carers allowance stand, all unpaid carers, of any age, studying part-time at advanced or non-advanced level will still be eligible for the carer support payment. Those who are aged 16 to 19 and are studying full time at advanced education level will be eligible for support, and those over the age of 20, regardless of their level of study, will be eligible for support. The proposal, as it stands, creates a distinction between those in advanced and non-advanced education. That can result in young unpaid carers who are aged between 16 and 19 and in non-advanced education feeling that their level of study is inferior and that they are undervalued in comparison to other young carers.

A key point made by the Scottish Government is that the carer support payment is an income replacement benefit, and young carers aged 16 to 19 who are in non-advanced education are not expected to be income earners. Support may be provided through parents or guardians, child benefit and universal child tax credits, if they are on low incomes. However, many young people aged 16 to 19 who are in full-time, non-advanced education—remember that that is not just those in school; it is those studying under higher national certificate level at college—supplement their finances with paid employment. For many young adult carers, balancing paid employment, full-time study and caring responsibilities is simply not possible.

It is also really important to highlight that our research shows that student carers are four times more likely to drop out of college or university, and financial pressure has been identified as being one of the key pressures behind that. It adds complexity, which we think is unnecessary. As I said earlier, I would like to see the evidence and the rationale for the decision to exclude only those who are aged 16 to 19 and in full-time non-advanced education.

Thank you. Fiona Collie, do you want to add anything to that?

Yes. On the issue of non-advanced education, across the piece, young people want to study and achieve different things. Some of the things that are described as non-advanced are qualifications and support to help young people become job ready, and there is a possibility of them missing out on support completely and perhaps making different decisions. So, there is the possibility of unintended consequences from restricting the benefit. It is about fairness and equity. You do not need to be doing something at advanced level or HNC level to be doing something towards your future. We need to support our young people who are in that position, particularly young carers.

Thanks very much. That was helpful.

Good morning. The regulations as laid provide for full-time young carers in non-advanced education to access carer support payment in exceptional circumstances, such as when they have no parental support. Is that sufficient? Does the eligibility need to be widened?

One of my concerns is about societal stigma. What are your comments on that, given that the process touches on someone being without parental support? How do we widen eligibility if a stigma is attached, and how do you combat that? I am looking at Fiona Collie, but I would not mind hearing from Paul Traynor and Maggie Chiwanza as well, especially on stigma.

I will pass this one over to Paul Traynor, because Carers Trust Scotland and the Scottish young carers services alliance have been doing a lot of work on that.

We welcome the extension to those with exceptional circumstances. To go back to the previous question, that also adds an extra layer of complexity to the system. As we have stated in our submission, and as we have said throughout the consultation process, we believe that the Scottish Government should extend the carer support payment to all unpaid carers in advanced and non-advanced education. It would add an extra level of support for many young carers who might be in situations that would fit within those exceptional circumstances, but, as I said, it just adds to that wider complexity.

In relation to stigma, Social Security Scotland has the ethos of dignity, fairness and respect. It is really important that benefits are recognised as an entitlement. If young carers come into the fold of entitlement for the carer support payment, it is about income maximisation and ensuring that they get the financial support that they need and deserve. It takes a cultural shift, because it will be the first time that many of those children and young people will have interacted with the benefit system. Support, information and a lot of outreach is required to ensure that those young people, first of all, know that they are eligible. There also needs to be support around how they can apply and the processes for doing so.

I agree with what my colleagues have said. Some of the minority ethnic young carers whom we support already have a cultural belief that it is their duty to look after their parent or grandparent. If they have to interact with social security to access carers allowance or the carer support payment, it is important that the information is clear. They need to be well supported in claiming for that and advised that they can do so, because there is an issue to do with confidence as well: they can feel guilty. We have experience of that, and we have told them that they need to do that because it will help them on top of their studies or the part-time work that they may be doing.

09:15  

I will rephrase my question slightly. My understanding is that the complexities would add to the stigma, and I just really wanted your comments on that. Do you agree that that is the situation?

Yes and no, in terms of how it has been set up. If there was information and clear messaging about what those changes are, that might really help to explain things; they could understand that. The process has always been complex, but it is more complex when there are changes and people are not very clear about how to go about that.

I direct my question to Paul Traynor, in the first instance. Witnesses have argued that eligibility for the young carer grant should be extended to 19-year-olds. I understand that the Scottish Government is considering that. Is that a change that needs to be prioritised? If so, why?

That definitely needs to be considered. In our written evidence to the committee, we say that, if the policy were to be progressed as presented, it would be deeply unfair that 19-year-old young adult carers studying in full-time non-advanced education would not be entitled to either the carer support payment or the young carer grant. It would mean that they would be the only unpaid carer group over the age of 16 that would not be entitled to any financial support at all. We do not believe that that would be treating that cohort of young adult carers with the Social Security Scotland core values of dignity, fairness and respect. Instead, the immense contribution that those young people provide to their cared-for person and to wider society would be undervalued and would go without financial recognition. It would create an anomaly for people aged 19 if the regulations were to be passed as planned. It is about fairness, equity and the recognition of young carers. That is a priority that should be addressed in the regulations.

At the risk of repeating what has been said, I think that such a change should be an absolute priority. The Government should bring forward amendments to the regulations on the young carer grant as a matter of priority. I am sure that the loophole was not intended, but we need to find a way to close it.

I will bring in Marie McNair, who joins us remotely.

Good morning. I thank the witnesses for their time. I will cover the issue of overpayments, but my general observation is that there is much to do after safe and secure transfer. Carers allowance has been around for a long time, and it does not meet the needs of carers. Given the long-standing flaws, has the UK Government made any efforts to consider major reforms?

Some work has been done in that regard. At a UK level, our organisation has been involved over a number of years in improving forms. The issue of overpayments is really challenging. The House of Commons undertook an inquiry into it, and, as part of that, the National Audit Office found that very few overpayments were proven to be the result of fraud. In a lot of cases, earnings were slightly over—sometimes by as little as £1—or the issue was to do with someone having fluctuating earnings.

There is a real challenge in getting things right with the carer support payment from the beginning, but we have a real opportunity in that regard. The cliff edge in relation to the benefit means that carers can end up owing hundreds, if not thousands, of pounds in overpayments, so we need to get things right with the new carer support payment.

I totally agree. The issue of overpayments is a real concern.

Judith Paterson, SCOSS made recommendations on the issue. Are you satisfied with the Scottish Government’s proposals to deal with overpayments?

To some extent, overpayments are an inevitable consequence of entitlement being dependent on earnings. Therefore, SCOSS took the view that tackling the issue required redesigning systems and entitlement rules. We made a number of recommendations about the systems to mitigate the risk. It is the first time that Social Security Scotland will have administered such an earnings test. It is complex, with lots of new systems to set up, so one of the most important things is to learn lessons quickly so that problems that arise can be picked up before they get embedded.

As Fiona Collie said, we have already learned a lot of lessons from the UK system, so we know what to expect. We know that having the right data feeds from His Majesty’s Revenue and Customs to pick up changes in earnings—by and large, overpayments are caused by earnings not being reported, picked up and acted on quickly enough—is very important but not sufficient. We also need to have staff who are ready to act quickly on the data.

We have made a number of other recommendations on systems. The Scottish Government has accepted them all, and we are pleased about that. We would like it to go further, when it can, on making changes to entitlement rules. We understand why that cannot be done until after safe and secure transfer, and we agree that there should not be a two-tier system, but we think that, to mitigate the issue of overpayments, the Government will need to simplify the earnings rules.

The level at which overpayments are reclaimed is a little bit concerning. We need to make sure that the level that is set is reasonable. I re-emphasise the fact that the National Audit Office found that very few overpayments were the result of fraud rather than simple mistakes. The new system should try not to be as harsh, and it should not seek repayment for simple errors. Setting an arbitrary level is not helpful. There needs to be a little bit of thought on that, because—I emphasise it again—very few overpayments are the result of fraud.

Roz McCall would like to come in.

Marie McNair has raised some valid points with Judith Paterson and Fiona Collie. As Judith Paterson said, overpayments are an inevitable consequence, but we are looking at how Social Security Scotland can minimise the issue. That raises the question of what we do when there is an inevitable consequence. What do you suggest that we should do when overpayments occur? We are talking about what we need to do, but I am interested in what you think we should do.

We have made quite a few recommendations. First, the number of overpayments should be reduced to a minimum. In other words, they should be designed out of the system in the first place, because we know that the consequences for carers—having to repay the debt over time and having to deal with the financial consequences—are distressing. Mistakes are mistakes; they are not deliberate. It is about designing those out.

We made a couple of recommendations that have been partially accepted. Fiona Collie alluded to one of them, which is that small overpayments could be written off. The Department for Work and Pensions will write off an overpayment of £65. We recommend that Social Security Scotland should also write off small overpayments. However, £65 is less than a week’s worth of carer support payment, so is that the right level? The Scottish Government says that it does not have enough robust data to know how much it would cost to recover an overpayment, but it strikes me that £65 might be setting the bar quite low. It could be better for carers and for Social Security Scotland if we looked at that level.

The other important thing is that people who have been told that they have an overpayment and that it must be recovered have no right of appeal. That does not sit very well with the rest of the system. Generally, there is a right of appeal against any determination, and people’s rights to social security come with a right to appeal, but there is no such right in this case. That is being looked at, and SCOSS would like to see that changed quickly so that people can appeal.

Maggie Chiwanza and Paul Traynor want to come in.

My comment is on overpayments. The recommendation is to ensure that the system is designed so that there are minimal issues in that regard, but the concern is about when people have a caring role and their earnings change. They might be trying to adjust to new employment, or they might be trying to focus on the caring role, so some of those things can be easily missed. As Fiona Collie said, the number of such cases will be low.

I suggest that we try to find a way to have a degree of flexibility in how the issue is managed with individuals, because one shoe does not fit all people. People have different circumstances and situations, so we should have a dialogue to ensure that people who are already in situations of distress—they are stressed and dealing with all sorts of things—are supported in an empathetic and compassionate way while we find a solution. That might include discussing how long the person will repay for so that they do not get into debt, or there might be the option for the money to be written off, because they are already working hundreds and hundreds of hours and saving the Government a lot of money.

I will bring in Paul Traynor, but I remind everyone, because of time constraints, to keep their answers as concise as possible. Thank you.

I completely agree with everything that colleagues have said. The majority of overpayments are a result of unpaid carers not notifying the DWP of information on earnings on what are deemed to be reasonable practical timelines. The onus needs to be on Social Security Scotland to ensure that there are systems in place that make it easy for carers to declare their income in an understandable way, with clear information and processes for them to report on that.

Marie, do you have any further questions? If not, we can move on.

With your indulgence, convener, I have one further question. There was a really good discussion there about overpayment, but does the risk of overpayment outweigh the benefit of allowing advance applications and advance payments? That question is to whoever can answer it.

Fiona Collie would like to come in on that.

09:30  

In relation to advance payments, the proposal around when a person can apply for carers allowance, which is now carer support payment—I am still caught in the old language—is to reduce those advance options. At the moment, if somebody is claiming a disability benefit, they can look to claim carers allowance at the same time, so it makes little sense for someone not to be able to put in an application for carer support payment. There is something to be said for making the system as simple as possible for individuals, because carers are already dealing with enough. I do not think that those factors outweigh one another, but ensuring that people can make applications at the earliest point is critical.

Paul Traynor, do you want to comment? No. Okay. Back to you, convener.

I invite Paul O’Kane to ask a question.

Good morning to the panel, and thanks for being here. I am interested in future changes and the pace of those changes. We know that the business and regulatory impact assessment set out four policies for introduction once case transfer is completed, including on things such as wait times and what happens after a person dies. Which of those proposed changes, or what changes more generally, should be prioritised after case transfer and why should we prioritise in that way?

I appreciate that Paul Traynor and Maggie Chiwanza have been on the advisory group, so I will perhaps start with Paul.

It is difficult to see the right order in which to prioritise those aspects. Extending eligibility will ultimately ensure that more unpaid carers get the support and recognition that they need and deserve. There are precedents: if we look at the young carer grant, we see that aspects of combining hours already exist in that policy. In some cases, we would like a clear timeline drawn up by the Scottish Government to show when the changes will be made. Some of the changes, such as the introduction of the additional payment for those who care for more than one disabled person, may be more complex than others, such as extending the run-on period when a cared-for person dies from eight weeks to 12 weeks.

I would say that the priority is to move forward on those changes as quickly as we can to ensure that the entitlement is extended to carers. If some of those things can be done more quickly, they should be done in a timely way. What is missing at the moment—I recognise that it is difficult at this stage—is clear guidance on when they will happen. I recognise that some things are a bit more complicated, such as introducing the new payment for those who care for more than one disabled child. I appreciate that that might take longer to come in.

I have no comments to add. I agree with everything that Paul Traynor has just said.

Fiona, do you have a view? I imagine that yours may be similar.

The timeline is critical. We need a clear plan so that we are ready to go when safe and secure transfer has happened. Some changes are simpler than others, and it would make sense for those to move more quickly.

Fundamentally, some things, such as putting more money into carers’ pockets, are critical for those who are caring for more than one person. Equally, we could make some changes around the earnings threshold relatively easily by changing the figure for that threshold. At the moment, it is about 13 hours at the minimum wage, and then you lose all entitlement. Even if we were to bring the threshold up to 16 hours at the real living wage, that would put an extra £2,000 a year into carers’ pockets. In some ways, the system would already be in place, so, in my view, it would be about adjusting the figures.

I definitely understand the attraction of trying to get the simple things, like the run-on, changed very quickly. Fundamentally, the priority is to get more money into carers’ pockets.

Helpfully, the Government’s timescales are the subject of my next question. You expressed the desire to see the changes happen as quickly as possible. The Government said:

“We recognise that Carer Support Payment from launch will not immediately fully achieve all of the aims … for carers. These aims are intended to continue to guide the development of the benefit on an ongoing basis.”

That is quite woolly. What discussion has there been with the Government about the hard-and-fast timescales that people are looking for?

I will bring Paul Traynor back in, because he started on this topic.

At present, I am unaware of any discussion with the Scottish Government on timelines for when the changes will be made. All that has been said to us as a national carers organisation and publicly is that, after the case transfer process?recognising that the Scottish Government has highlighted aspects that it is committed to introducing, including the run-on period and the additional payment for those who care for more than one disabled person?its overarching commitment is to explore and consider a range of other aspects.

As we highlighted in our submission, we would like some of the points in the commitments that have been made to be accelerated. Addressing underlying entitlement is a key point on which we would like to see some movement. In the list, however, and even in the Scottish Government’s response to SCOSS and from consultation, that seems to be quite low down the priorities, as a longer-term consideration.

You mentioned SCOSS. It has responded on trying to achieve the broader aims, so would Judith Paterson like to come in at this stage?

Yes. It was apparent that the aims of carer support payment are broader and more ambitious than those for carers allowance, the aim of which is essentially to replace earnings. Carer support payment also aims to recognise the caring role that is undertaken by unpaid carers. In talking to carers, SCOSS heard that they did not feel that their caring role was valued. Certainly, from launch, the wider aims will not be achieved by carer support payment, so more changes will need to be made to achieve those aims.

The structure of carers allowance is much the same as it was in 1976, when it was first introduced, so a review is well overdue. It is welcome that the Scottish Government has done a lot of advance work to be ready to introduce changes as fast as possible. That work will mean that there is no reason why it could not happen more quickly, after safe and secure transfer is complete.

On which changes should happen first, the only view that SCOSS took was that redesigning the earnings rules to reduce some of the barriers for carers who want to work should be feasible and a priority. We did not take a view on when other changes should be made, but, for the carers to whom we spoke, it seemed that changes that are aimed at recognising their role were a priority.

Good morning, everyone. The business and regulatory impact assessment associated with the legislation states that there should be

“an improved service from launch”

of carer support payment. We have heard that incremental improvements and changes will be made further down the line. Everyone understands that but, at the start, from day 1, what should that improved service look like?

Fiona Collie was trying to come in towards the end of the previous question, so I will go to her first.

First, it is about simplicity and being able to apply for and access the benefit. The ability to apply in different ways is critical. We need to make sure that the right information is available, because it will be a change, and two different systems will be running at the same time, particularly when we are working with pilot areas. We therefore need to make sure that we get the right information out to people about carer support payment, and we need to make it as simple as possible.

Another area where we need to do better is that, at the moment, people who have an underlying entitlement might get a letter saying, “You’re entitled, but we’re not going to pay you. You can take this letter somewhere else.” That is normally related to the pensions service and people who might be eligible for pension credit. We need a simple system that enables individuals to assess their eligibility without submitting a full application, for example. We need an agreement among the Scottish Government, Social Security Scotland and the pensions service to be able to share information. We want to make the process as simple as possible, because carers who are on the state pension, even if they get a penny of pension credit, could be eligible for council tax reduction, help with their rent or other things. We therefore need to make some of those things as simple as possible as well.

You might have strayed into what my next question was going to be about.

Oh, sorry.

Perhaps not. I will ask it now. After I have asked it, I will bring in Fiona, and maybe Paul Traynor could come in after that—I see him nodding his head—for the best use of time.

At the launch, carers will be signposted to other support—some of the signposting will be there—but the provision of wider support is meant to develop over time. I think that we were starting to move into that kind of area. What are your priorities for what the wider support should look like to make it meaningful for carers?

Income maximisation is critical. I am a bit wary of signposting, because that puts a lot of onus on the individual. There is more that Social Security Scotland can do on income maximisation, particularly when it comes to local advisers making sure that individuals are accessing the reserved benefits system and other supports that are available. For example, that might mean understanding and knowing that there is a carers centre and being able to make a formal referral, if possible. It is about some of those things. It makes sense to make it easier for carers at every step of the journey.

That is a fair point. For clarity, this is about initial signposting. The wider support should follow on from that—in short order, I hope.

Paul, do you want to add anything?

09:45  

I completely agree with everything that Fiona Collie said. The only aspect that I would add is about ensuring that carers can get that information. Social Security Scotland does not provide advice on reserved benefits, and one of the most underclaimed benefits, particularly for those with underlying entitlement, is pension credit. We would like to see more information for carers, particularly for those who apply for carers allowance and are told that they are not eligible due to underlying entitlement, on the wider support that is available to them, such as that which Fiona highlighted.

We would also like to see those who are in receipt of carers allowance or carer support payment and who are going to lose their entitlement, such as those who are approaching the state pension age, being sent information much further in advance of losing that entitlement. We recently heard from an older adult carer who said that they were only informed that they were going to lose their entitlement two months before they lost it. As we know, the application process for other benefits can be quite time consuming. We would like the notice period to be increased to at least six months for those approaching state pension age and with an underlying entitlement, so that they have information in advance to make informed decisions. Social Security Scotland could look to introduce that as part of its communication process with carers.

Thank you, Mr Traynor. I have a final—

Before you move on, I think that Maggie Chiwanza wants to come in.

My apologies, Maggie; I was not aware of that.

That is fine. Thank you.

I agree with what Fiona Collie and Paul Traynor said. I would like to look at the issue through an equalities lens. To make an improved service, it is essential that the information that is provided is accessible, clear and unambiguous. If it is not, for some of the equalities groups that we represent that have literacy issues or language requirements, it can pose a challenge by heightening anxiety. So, information is very important, and it is very important to make it very easy for people to access the services.

That is a helpful comment, Maggie, because my final question was going to be about whether we should expect additional applications as a result of the change to the Scottish carer support payment. It is forecast that, in 2025-26, we will be paying out £32 million more than we would have been had we stayed with the carers allowance at UK level. That means more money going into the pockets of carers, which is a good thing, but only £7 million of that relates to the increased eligibility criteria, which include, for example, advanced full-time education applicants. The rest of the cost is assumed to be the cumulative impact of more people applying for the new payment. That goes back to Maggie Chiwanza’s point about clarity and accessibility.

Does any of the witnesses want to say a little more about whether the new payment will mean that people who currently qualify for carers allowance and carers allowance supplement but do not apply for it will be emboldened to do so? Is this an opportunity? Fiona Collie is in the room and she is nodding her head.

Absolutely. We will have positive information around the new payment for carers so, inevitably, those who may not have claimed before may come forward and claim. Equally, people who are receiving the carer element under universal credit might consider claiming the carer support payment, which would then make them eligible for the carers allowance supplement. So, there are two strands to that but, yes, absolutely.

I believe that Maggie Chiwanza wants to come in. I am conscious of the time, so I ask you to be as concise as possible, Maggie.

There is a real opportunity to increase the uptake from minority ethnic communities. We know that the uptake is low at the moment and, by providing good information and support, there is a real opportunity to improve that.

Thank you very much. I now bring in James Dornan, who joins us remotely.

Thank you, convener. This question is for SCOSS. Do the regulations as laid accurately reflect the Scottish Government’s policy intentions?

Thank you for that question. In our view, it is the most complex benefit to have been devolved so far, given the multiple interactions that there are with reserved benefits in particular but also with existing Scottish benefits. The carer support payment interacts with the young carer grant. In those areas, in particular, we saw challenges in drafting the regulations accurately in order to cover those interactions. We identified those issues and, as we went through the scrutiny process, we talked to the Scottish Government and, in response, it made changes, where it could, through the process. We had sight of those changes in new drafts of regulations, and that was fine.

With some of the recommendations that we made, we did not see the resulting change, although the Scottish Government accepted the recommendations that we made. In its report to SCOSS, it helpfully set out its response in detail, so it seemed to us that the issue was communicated and understood. However, I cannot say that SCOSS went back and conducted follow-up scrutiny of the regulations as laid. We have not cross-checked that all the changes that the Scottish Government accepted and said that it would make in response to the recommendations now completely reflect the policy intention.

Okay. So, at this stage, you are not quite sure whether it is completely tied up.

This question is for you and the other witnesses. Are there any other issues with the regulations that you wish us to highlight for discussion with the cabinet secretary when she comes next week?

We made quite a lot of recommendations and they have all been accepted, either fully or, in some cases, partially, so I am content that SCOSS has made the case that we wanted to make.

Thank you very much. Does anyone else wish to comment?

I believe that Fiona Collie would like to come in.

There is an area of concern around payment frequency. Currently, individuals can receive weekly payments under the carers allowance. Under the proposals as laid, that would be the case only for those who were caring for someone with a terminal illness. That is important, because those who will be safely and securely transferred will be given the option of four-weekly or weekly payments, but they will not be able to change back. More thought needs to be given to individuals having the flexibility to choose how a benefit is paid to support their family financial situation. We have a few concerns around that.

Thank you, Fiona. That is really helpful.

We have come to the end of our questions. I thank all our witnesses for taking part and sharing their expertise. I suspend the meeting to allow the witnesses to leave and to allow us to set up for our next item of business. Thank you very much for joining us today.

09:52 Meeting suspended.  

09:55 On resuming—