Report on Draft Budget 2014-15
Summary of Key Recommendations
The Draft Budget 2014-2015
The Scottish Welfare Fund
Council Tax Reduction
Value for money
Annexe A: Extracts from the Minutes of the Welfare Refrom Committee
Annexe B: Oral evidence and associated written evidence
Annexe C: Correspondence from Committee to other subject Committees
Report on Draft Budget 2014-15
The Committee reports to the Parliament as follows—
Summary of Key Recommendations
The Budget process
1. The Committee recommends that for future budgets, where possible—
- There should be single, consistent totals for expenditure;
- That complementary external sources of funding should be identified explicitly, but not included in those totals;
- That no expenditure should be cited in budget documents which is not associated with an identifiable cost; and
- All statements of expenditure should be stated over the same time frame.
- Available breakdowns of costs should be offered. [paragraph 13-14]
The Scottish Welfare Fund
2. The Committee commends the actions of the Scottish Government in supporting the scheme and protecting the vulnerable and recommends that the Scottish Welfare Fund be continued at the proposed level in 2014-15. [paragraph 49]
- Local authorities should be encouraged to share best practice with regard to the operation of alternative mechanisms of support following claims for the Scottish Welfare Fund. [paragraph 38]
- To inform future budgets the Scottish Government should identify all the sources it makes available for crisis funding and for community care and the total expenditure associated with them. [paragraph 39]
- To determine the relative contribution made by the different strands, it will be necessary in future to obtain information about which categories of potential recipient receive Community Care Grants. [paragraph 41]
- The Scottish Government and local authorities should establish appropriate criteria and mechanisms to ensure that information is captured on the category and outcome of the claim. [paragraph 45]
Council Tax Reduction
3. The Committee commends the actions of the Scottish Government in protecting the vulnerable and recommends that the Council Tax Reduction Scheme be continued. [paragraph 80]
- The Scottish Government should ask the UK Government whether the scheme can continue to be operated in tandem with Housing Benefit. [paragraph 72]
4. The Draft Budget 2014-15 was published by the Scottish Government on 11 September 2012. This report details the findings of the Welfare Reform Committee’s scrutiny of these proposals.
5. The Committee held two oral evidence sessions, including round-table discussions of Council Tax Reduction and the Scottish Welfare Fund.
6. The Committee also heard evidence from Nicola Sturgeon, Deputy First Minister and Cabinet Secretary for Infrastructure, Investment and Cities. Briefings were provided to the Committee by its Budget Adviser, Professor Paul Spicker. The Committee would like to thank all those involved in providing evidence to support the budget scrutiny process.
7. The Committee decided to focus, within a very wide ranging agenda, on two elements in particular: The Scottish Welfare Fund, and the Council Tax Reduction. These measures place an important responsibility on local authorities to deliver services and social protection for the most vulnerable.
8. This report consequently focuses on three key areas—
- The Draft Budget 2014-15, as it applies to welfare reform;
- Council Tax Reduction; and
- The Scottish Welfare Fund.
9. The first briefing report to the Finance Committee from its Budget Adviser, Angela Scott, considered the budget process, prioritisation and value for money as fundamental principles of financial scrutiny.1These principles have been recognised in the approach taken by the Welfare Reform Committee to its budget scrutiny. The Equal Opportunities Committee requested all committees consider the impact of reforms on equalities, and the report also considers the impact of budget measures in that light.
The Draft Budget 2014-2015
The Budget process
10. The budget presents the steps taken to mitigate the consequences of ‘Welfare Reform’ in several ways, including—
- a global total of £68m, consisting of—
- Scottish Welfare Fund £37.6m
- Council Tax Reduction £23m
- advice and support £ 7.6m
a range of policy measures, including some measures costed across two years—
- Housing Association advice services £ 2.5m across two years;
- advice services £ 5.4m across two years.
- Enterprise Ready Fund £6m
- capacity and resilience building in the 3rd sector £ 2.5m across two years.
further references to additional spending by other routes—
- Discretionary Housing Payments £20m additional in current financial year and further £20 million 2014-15 2
- early years intervention £15m to 140 3rd sector organisations
- various pilots and schemes to prepare the transition to Universal Credit
- the contribution of the Child Poverty Strategy
- the delivery of passported benefits
- partnership work with local authorities and the third sector
11. The presentation of the Draft Budget3 could be enhanced—
- The Scottish Government could do more to clearly show the welcome additional contribution that it has made towards mitigating the impacts of welfare reform. For example, in relation to advice services, Scotland has received £1.7m per annum as Barnett consequentials between 2013-14 and 2014-15.4 The extra money allocated by the Scottish Government gives an overall projected expenditure for advice of £7.9m up to 2015.
- Two values are given for the Scottish Welfare Fund: £33m5 and £37.6 m6. The latter figure takes account of the £4.6m for administration.
- The £5.4m towards advice work on page 9 is presented as £7.45m on page 124. The higher figure includes £2.35m from Money Advice UK;7 that is explained indirectly on page 140.
- The contributions of various measures are not clarified.
- No explanation is given in the Draft Budget of the additional £20m for Discretionary Housing Payments, or what it is additional to.
12. When asked about budget presentation the Deputy First Minister commented—
“John Swinney […] has gone to great lengths—and continues to do so—to satisfy two aims: to make the budget as clear as possible by bringing together different budgets in one area, such as welfare reform; and to ensure that one year’s budget can easily be compared with a previous year’s budget. The Government is open-minded and wants to do that as well as we can, and if the committee has any specific suggestions we will be happy to hear them”.8
13. These are problems of presentation, not faults in the budget. The Committee recommends that for future budgets where possible—
- There should be single, consistent totals for expenditure;
- That complementary external sources of funding should be identified explicitly, but not included in those totals;
- That no expenditure should be cited in budget documents which is not associated with an identifiable cost; and
- That all statements of expenditure should be stated over the same time frame.
14. There are no level 4 figures for welfare reform mitigation given in the Draft Budget, but there is supplementary information available from a range of sources, and it would be possible and consistent with the budget process to present the details in a more accessible and transparent format. For example, the component elements of the Scottish Welfare Fund can legitimately be described in terms of the nominal allocation to Community Care Grants (£23m), Crisis Grants (£10m) and Administration (£4.6m). The figures would be clearer, and easier to understand, if the statements of cost also distinguished and labelled complementary sources of funding (e.g. the contribution of £2.35m from Money Advice UK to advice services). The Committee recommends that in future budgets available breakdowns of costs should be reported.
The Scottish Welfare Fund
15. The Scottish Welfare Fund (SWF) is a discretionary scheme introduced as successor to the Social Fund (or, more precisely, the discretionary elements of the Social Fund - Crisis Loans, Budgeting Loans and Community Care Grants). It offers two kinds of grants, Community Care Grants (CCGs) and Crisis Grants. Amendments were made to the Guidance in October 2013 to clarify eligibility and roles. The Scottish Government’s legislative programme 2013-14 includes proposals to introduce a Bill that would put the SWF on a statutory footing.
16. The Department for Work and Pensions (DWP) transferred the money spent in Scotland on the discretionary elements of the Fund to the Scottish Government. This amounted to £23.8M in 2014-15 plus £4.6M to cover administration. The Scottish Government is continuing to add £9.2M into the new Scottish Welfare Fund giving a total of £33M for programme funding. Although the budget is unified, £23m of the Fund (70%) is intended for CCGs, and £10m is intended for Crisis Grants. Local authorities are free to vire between the allocations.
17. There are several potential interpretations of the role of the SWF. The Fund may reasonably be represented as—
- a safety net provision to deal with emergencies, crises or disasters. This implies a service that is flexible, responsive and rapid.
- funding mainly for poorer people. Both the initial guidance, subsequently moderated, and some of the processes initially used seemed to suggest that the receipt of qualifying benefits was required; these expectations have posed some barriers to access, and seem to have been discontinued. It is probably still true to say, however, that the fund is directed at people who are poorest, responding reactively to serious risks to health and safety. This implies a focus on targeting and priority setting.
- a form of holistic, preventative spending. The Guidance suggests that CCGs, in particular, should be planned and preventative9; the point was emphasised both by the Deputy First Minister and by representatives from COSLA. This seems to imply a service that is proactive, referral based and working to specified criteria, rather than one which is reactive.
18. CCGs tend to be substantially larger than Crisis Grants. The Scottish average CCG is £550, but six local authorities have averages from £302-£360, and 5 range from £687 to £937. The average for Crisis Grants ranges from £44 to £88, with 20 local authorities ranging from £51-64.10 There is considerable variation in the proportion spent on CCGs and Crisis Grants, ranging from 49% to 94% of funds used for CCGs. On current figures, 19 local authorities spend more than 75% of the funds they use on CCGs, and only five spend less than 65%. Local authorities have full discretion to vire between budgets, and this balance may change as practice develops.
19. The Deputy First Minister argued that the Scottish Welfare Fund offers an opportunity for joined-up services—
"The advantage of having these funds devolved and administered by local authorities is that local authorities are able to join them with the other bits of support that they are able to provide."11
20. This aspiration calls on services to collaborate, to establish systems of liaison, protocols and an agreed division of labour12. Some local authorities have developed their practice to do this.
21. Currently, however, the needs of different groups might be met through a range of systems. Local authorities have long-standing powers to make ‘direct payments’ for persons in need, under s.12 of the Social Work (Scotland) Act 1968.13 The people covered include those needing care and attention arising out of infirmity, youth or age; people with illness, mental disorders or disabilities; and persons subject to immigration control, including asylum seekers. Guidance from one local authority explains "Assistance in cash can only be given in exceptional circumstances constituting an emergency."
22. Local authorities are also able to make provision for financial assistance to children in need, by s.22 of the Children (Scotland) 1995 Act.14The same authority's guidance under this section explains—
"All sources should be explored before offering cash payments, in exceptional circumstances, and no repayment can be requested ... Staff should establish that the person is without funds and/or food to meet their children’s needs until income is available."
23. Further payments for the purposes of community care and furthering independent living are available in the context of support for community care.15This means that the SWF is not the only form of discretionary provision available; and although it is intended to be ‘holistic’,16 there are overlapping, parallel provisions which are also holistic. To establish the priority and effectiveness of expenditure, it would be helpful if the systems of reporting were developed so that a comprehensive view of the effect of financial assistance could be taken.
24. All benefit systems need to have a safety net for emergencies - some discretionary provision for unforeseen circumstances. Criticisms of the Scottish Welfare Fund’s predecessors (Exceptional Needs Payments, Single Payments and the Social Fund) often related to the use of funds for circumstances that were predictably the consequence of low income, rather than exceptional circumstances: people who run out of money for food are not going to have resources available for replacing other necessities. That is a criticism of the level of benefits overall, rather than of the existence of provision for crises, or the operation of discretion.
25. The Scottish Government's Guidance states that Crisis Grants are intended to—
- "provide a safety net in a disaster or emergency, when there is an immediate threat to health and safety" 17; and
- "meet expenses that have arisen as a result of an emergency or disaster in order to avoid serious damage or serious risk to the health or safety of the applicant or their family".18
26. These instructions are not equivalent. The first refers generally to a threat to health and safety without qualification; the second requires it to be 'serious'. The first refers to immediate threat; the second to consequent expenses. This implies some scope for different interpretations of the role of the Fund, and so for inconsistent practice.
27. Another problem of interpretation has arisen from the suggestion that ‘normally’ those using the fund will be entitled to benefit.19 In their nature, urgent, unpredictable or emergency needs do not necessarily fit those categories. Recently the Guidance has been amended to emphasise that these conditions are not essential prerequisites; the Fund has to be used flexibly. The Committee welcomes the update made by the Scottish Government to the Scottish Welfare Fund Guidance.
28. There is a continuing dilemma relating to support for claimants who are not receiving help from the benefits system. Claimants may also be left without resources when DWP benefits are denied or fail to be delivered. The current guidance advises at the same time that DWP sanctions and disallowances must be respected20 and that grants may be given after the disallowance of Employment and Support Allowance while decisions are challenged.21 It may also happen that, despite the DWP's liability to provide Short Term Benefit Advances, a local authority might still find it necessary to make a payment while a claim to the DWP is still in progress.22
29. A scheme for use in crisis, emergency or disaster needs to be responsive, flexible and able to respond rapidly. At times the response may have been restricted. The margin, allowing for decisions up to 48 hours, may prove slow to deal with a crisis. Equally the focus on ‘one-off needs’ may not fit with crisis management. The restriction of the fund to three claims in any twelve months23, may not allow for the position of a claimant who has successive one-off needs stemming from the same crisis (payment in instalments may also be an option). Some administrators may have interpreted the criteria too restrictively or literally, leading to fewer grants being awarded. Beth Reid, of Citizens Advice Scotland, commented—
"We have seen a very small number of cases that have involved local authorities guarding budgets or applying the criteria very strictly without using any discretion. One or two of our clients have been told that they have to look at every other opportunity before they can come to the Scottish Welfare Fund. However, I have seen fewer such cases recently, so I am hopeful that the approach is beginning to work its way through."24
30. The Committee sought to explore the difficult question of consistency in practice. It is in the nature of a devolved scheme, operated by 32 local authorities, that some variation is necessary and desirable. At the same time, there may be sometimes more apparent variation than is reasonable, and the Deputy First Minister emphasised that "we do not want postcode provision".25 Douglas Proudfoot, of COSLA, commented—
"we have done a great deal with the Scottish Government and individual local authorities to secure consistency across the local authorities.26
“I have seen a lot of good practice, and I have also seen inconsistency and an element of decision making that is too harsh."27
31. Uncertainty about the grounds for priority or the scope of legitimate action may lead administrators to limit or postpone decisions. John Campbell, Financial Services Manager in North Lanarkshire, explained—
"The first question that was asked when people phoned in was perhaps on their eligibility and the guidance rather than on their need and what the crisis was. People were therefore told early doors that they would not qualify because they were not in receipt of a qualifying benefit, instead of being asked about the actual crisis. The trend from April through June, July and August into September has changed. As the staff gain more experience, they become more comfortable about eligibility, the guidance and ... their discretionary powers."28
32. Practitioners have been collaborating to develop common approaches, but it may take some time and further refinement of the terms for greater consistency to be possible.
33. Douglas Proudfoot noted that "The Crisis Grant is the only aspect of the awards system that is below the level at which it stood under the predecessor arrangements"; the average payment is £57.29The reduced spend may reflect a different approach to payment. Support may be given in cash or kind.
34. Anil Gupta from COSLA emphasised the role of local authorities in adapting the mechanisms to different patterns of support—
"We are much more convinced that the synergies that can be developed locally on service delivery and our ability to take advantage of cost-saving measures, such as providing in-kind support and goods, are important. We can also ensure that people are supported by other welfare provisions that run through local government. None of those synergies would be achieved by focusing just on the specific task of distributing money."30
35. Unlike the Social Fund which preceded it, the SWF does not offer loans. Local authorities in Scotland made loans on the basis of the Social Work (Scotland) Act 1968,31 before the Social Fund was set up;32 the power is still there.33 The current guidance in one local authority states—
"Assistance in kind or in cash can be given unconditionally or subject to repayment conditions, in whole or in part, as the Council considers reasonable, having regard to the person’s means and his/her eligibility for assistance from any other source. If the assistance is to be repaid, a suitable and enforceable loan document will require to be signed by the person seeking assistance."
36. Local authorities also now have a general power to promote welfare, which excludes social security but not loans. However, loans could not be made from budgets designated for the SWF.
37. The Guidance points to a range of non-financial support mechanisms - advice, income maximisation, signposting, advocacy and support for resilience. These measures are desirable, and there are examples where they have been used very effectively, but there is a risk that they may be perceived as a strategy of diversion, deterring legitimate claims. John Campbell of North Lanarkshire Council argued that there may also be some misinterpretation—
"The thing about the Scottish welfare fund scheme is that the decision may still be 'No' after the person has gone through the process, but rather than their being left with nothing and having to go and seek other advice and information themselves, which happened in the past under the DWP, the fund will say, 'We recognise that you have a need. While you didn’t meet our criteria, these are the things that are available in your area."34
38. There are no sources of information available as yet that can support closer scrutiny of the operation of alternative methods and strategies. The specific handling of the issues is a matter for local authority practitioners rather than the Scottish Government. The Committee encourages local authorities to share best practice with regard to the operation of alternative mechanisms of support.
39. In a crisis, families might be supported through Crisis Grants, CCGs for families under pressure or payments from social work (for example, under s.22 of the Children Scotland Act 1995). In the early years there is also provision for support via a range of groups in the Third Sector; the budget statement refers to a further £15m available to 140 such organisations. The relationship between the different services is unclear. The newly revised guidance asks local authorities to consider how alternative systems of support relate to each other and whether they are complementary.35This is important both for transparency and for determining the relative priority given to different groups. The Committee recommends that to inform future budgets the Scottish Government should identify all the sources it makes available for crisis funding and the total expenditure associated with them.
Community Care Grants
40. CCGs are additional to support given by local authorities for adult social care. The main aims are “to enable independent living or continued independent living, preventing the need for institutional care”,36 and to support 'families under exceptional pressure'. The groups identified as eligible go beyond categories normally identified with 'community care', including families, offenders and children leaving care. The revision to the guidance now states that there does not have to be a child for a claim to be considered as from a family, and it puts a particular emphasis on the protection of those who do not have a settled way of life, including people who are homeless. At £550, the average payment for a CCG is nearly ten times the average payment for Crisis Grants.
41. CCGs have a range of criteria and objectives, including some which are consistent with preventative expenditure (preparation for independent living) and others which may be interpreted reactively or as a response to urgent situations (‘help for families facing exceptional pressures and who lack the resources to meet irregular costs to provide a safe and secure environment for their children’).37 To determine the relative contribution made by the different strands, it will be necessary in future to obtain information about which categories of potential recipient are receiving CCG. The Committee encourages the Scottish Government and COSLA to consider how these statistics could be obtained.
42. COSLA has advocated a role for the Scottish Welfare Fund quite distinct from the former Social Fund, supporting ‘targeted’ preventative expenditure. Douglas Proudfoot, of COSLA, who has been a strong advocate of this position, argued that the Fund—
"provides a great opportunity for a lot of local authorities to target areas where take-up is lower—to go on the front foot, to work with third sector providers and to look at national health service links and links with older people, female prisoners and other groups that are for whatever reason marginally excluded—in order to make a difference. That applies particularly to community care grants, which are the more proactive aspect of the fund. By taking that approach, we could save in the future."38
43. However, sufficient information is not yet available on CCGs to access progress on these aspirations, to examine how the scheme can best operate in this way and to learn the lessons from its development. There were also doubts from the field. Beth Reid, of Citizens Advice Scotland commented:
"We have not seen much evidence of the holistic approach that was envisaged for the scheme, but I hope that it will develop as the scheme progresses."39
44. Community care is also part of the responsibility of social care services, which are required to assess needs, to arrange for appropriate responses and to allocate funds according. Within the system of community care, direct payments are increasingly being used in community care to offer finance for purchase according individual preferences, in place of services: £59.4m was provided for direct payments in 2012.40As the use of direct payments has grown, the Scottish Government has been encouraging a view of them as social care provision. While the legal powers governing payments are broad, they suggest they should be used primarily for long-term, predictable social care needs as part of a continuing relationship with clients. In so far as the aims are distinct, it should be possible to distinguish clearly the role of Direct Payments from CCGs, but at present the objectives overlap - both schemes provide for preparation for independent living - there is no clear division of responsibility, and there are no generally agreed protocols. In terms of budget scrutiny, that also creates potential uncertainty over the actual funding and level of priority accorded in different circumstances. The newly revised guidance emphasises the importance of establishing appropriate allocations of responsibility. This division of labour is primarily a matter for local authorities and practitioners, but the Committee recommends that to inform future budgets monitoring procedures should identify all the sources of support that the government makes available for community care and the total expenditure associated with them.
The demand for the Scottish Welfare Fund
45. The demand for the Scottish Welfare Fund is managed by a form of triage. Priority is identified in three categories (high, medium or low), according to the potential to resolve the issues (rather than the severity of the condition). In the first months, claims have been fewer than originally anticipated; there have been particular shortfalls on expected claims for Crisis Grants. The revised guidance suggests there may be a need for a fourth category, "high most compelling".41 This anticipates increasing pressure on the Fund. As things stand at present, however, the initial assumption that only ‘high’ need might be met has been relaxed, and some ‘low’ priorities have been met. Detailed information on the operation of the priority scheme is not yet available. The Committee recommends that the Scottish Government and local authorities should establish appropriate criteria and mechanisms to ensure that information is captured on the category and outcome of the claim.
46. The number of claims and the level of payments made have in most places been lower than initially budgeted for. There are several possible explanations for this, but in the absence of firm information all are speculative—
a. The scheme is new, and information is short. Anil Gupta, of COSLA, suggested that there may also be some misdirection from the DWP: claimants who apply for the Social Fund are told that the scheme has been abolished.42
b. Practitioners may have interpreted the conditions for grants more restrictively than the criteria formerly used by the DWP for loans.
c. Local authorities are diverting claims to other sources. Douglas Proudfoot, of COSLA, argued that this was desirable—
"Money is not always the answer for some of the people who we are talking about, with substance abuse and other horrible factors in play. Sometimes a monetary award is not the help or support that is required. However, there is an opportunity to work together at local level with many agencies—not just within the council—to provide a meaningful award that comes along with support and advice and makes a difference.”43
There are concerns that diversion prior to a claim may mean the claim is neither recorded nor subject to review.
d. Discretionary administration by local authorities, or the provision of goods in place of cash, is a deterrent. John Campbell expressed a doubt that people who owe the council large sums of money (for example, for Council Tax) would be ready to approach the same department, typically Revenues and Benefits, for a smaller amount.44
e. The scheme may have been difficult to access. The number of telephone calls to SWF staff is high: local authorities may typically be taking 500 to 1000 calls a week. The large volume of calls may have created difficulties of access. Beth Reid reported that Citizens Advice Bureau—
"are finding it difficult to get applications through. That is sometimes because of administrative issues, such as it taking a long time to get through on the phone line."45
f. The numbers are being counted differently, because claims for the SWF do not include requests for short-term benefit advances, which now go to the DWP. (The DWP has been reluctant to provide advances, but the SWF is not available for this use. This leaves an important gap in provision.) Andrew Hall explained—
"A lot of the inquiries that Shetland Islands Council has received have come from people who are looking for Short-Term Benefit Advances. We have quite a number of inquiries and the staff are knowledgeable enough to realise that there is no point in wasting people’s time by making them complete an application form."46
47. The shortfall on expected claims may indicate that the scheme is over-supplied, but it is too early to say; current plans already suggest a fall in real resource, and several witnesses suggested that pressures were likely to increase. The Committee supports the on-going monitoring by the Scottish Government of the number of claims made for the Scottish Welfare Fund.
48. The Committee welcomes the commitment made by the Scottish Government that any money not spent in this budget area this year by a local authority will be carried forward into the local authority’s budget for the next financial year.
49. It is clear that the extra funding supplied by the Scottish Government has made a substantial difference to the design, operation and character of the scheme by comparison with provision in England and Wales. The Committee commends the actions of the Scottish Government in supporting the scheme and protecting the vulnerable. The level of funding in the Draft Budget is reasonable and consequently we recommend that the scheme be continued at the proposed level in 2014-15.
Council Tax Reduction
50. Council Tax Reduction (CTR) has its origins in the system of Rate Rebate introduced in the late 1960s. Rate Rebate offered a reduction in liability for domestic rates. When Rent Rebate and Rent Allowance were introduced in 1972/73, they were designed on similar principles to Rate Rebate, and the three benefits were administered together. (Rent Rebates and Allowances were absorbed into the Unified Housing Benefit in 1982/83.) When rates were reformed into the ‘Community Charge’ or poll tax, Rate Rebate became Community Charge Benefit (CCB). With Council Tax, CCB was reformed to become Council Tax Benefit; that has now been replaced by CTR.
51. When the UK Government arranged for rebates of Council Tax to be localised, it also cut funding by 10%. In English local authorities, this has led to people who would previously have been entitled to a full rebate having to pay some minimum proportion of the Council Tax bill - sometimes at least 8%, sometimes 20%. The Council Tax Support schemes introduced in England are complex, but 232 councils - 71% of local authorities - have met the shortfall by requiring recipients to pay some proportion of the council tax, regardless of income. The schemes are highly localised, with differences in eligibility and rules for different band rates.47
52. The recipients of CTR tend to be either pensioners, or people in households where no-one is working. Most people in certain categories are entitled to CTR, but very few are in others. Among single parents who are not working, only 7% are not entitled; among couples where neither is working, it is 11%. By contrast, 88% of households where someone is working are not entitled.48 Cuts in benefits are likely to be focused on people of working age. Les Robertson of Fife Council and IRRVS explained that the decision to protect pensioners has important implications for other groups—
"Down south [...] it was decided that they could not increase the bills for pensioners, so local authorities were told that they would have to protect pensioners and that that would be part of the default scheme and of any scheme that was introduced. In Scotland, probably more than half of our customer base are pensioners. Thus, if (such) a scheme were introduced, a 10 per cent cut to expenditure would affect only working-age customers and would have to be a 20 per cent cut."49
53. The national scheme introduced in Scotland has largely avoided the problems being experienced in England. The Scottish Government has made £23m available to fill the gap in funding. The shortfall in funding is however £40m. Local authorities have to provide the remaining £17m. They effectively make their contribution by operating the national scheme, which means that they forego income. The local authorities have accepted this position for 2013-14 but they have reserved their position for future financial years.
54. The Committee welcomes the steps taken by the Scottish Government and local authorities to work together on the provision of this scheme, which has avoided some of the difficulties being experienced in England and Wales.
55. Dr Peter Kenway, of New Policy Institute explained in his evidence that—
“The most important aspect of the localisation of council tax support in England is not the local design of the schemes but the localisation of the financial risk away from the UK Treasury.”50
56. The policy in England has subjected local authorities to significant risks: for example, the effects of losing a local employer might increase the number of claims. Les Robertson of Fife Council and IRRVS identified similar risks in Scotland—
"Under the new scheme, if something happens such as Hall’s of Broxburn closing down, the increase in case load will be borne by the local authority—and that local authority only."51
57. This position has also, Dr Kenway, of New Policy Institute suggested, created a financial incentive for authorities to avoid assuming responsibility for people receiving benefits—
"A sign of that is that a very small number of English schemes have introduced a residency requirement. In a couple of cases, I think that a person must live in the area for five years before they are entitled to council tax benefit. Areas that have high levels of bed and breakfast or high levels of people moving in are trying to protect their budgets ... the potential is there for local authorities to want to get rid of and keep out people who need council tax benefit, because of the burden that that imposes on their budget."52
58. By intervening, the Scottish Government has protected local government from some of the worse effects. The problem remains, however, that the Scottish Government contribution is fixed and that local authorities have to absorb any variable costs. The Deputy First Minister commented—
"I suppose that the honest answer is that I cannot protect local authorities completely from that ... We are facing a policy programme that is not of our making and we do not have control over its impact."53
59. Susan Mathers, of Falkirk Council, argued for a more flexible arrangement: there is, she explained—
"a fixed-term grant settlement, based on previous years’ case load. It does not reflect case load growth or movement. There is no mechanism for in-year adjustment of that, as there was with the former subsidy claim when we claimed direct from the Department for Work and Pensions. That needs to be there."54
60. The Committee would welcome further information from the Scottish Government on whether there has been any discussion with COSLA about applying to CTR the use of in-year adjustment to the grant settlement.
How Council Tax Reduction works
61. Council Tax Reduction (CTR) like its predecessors, is based on a ‘tapered’ means-test. Entitlement is withdrawn as income increases. Benefit entitlements are determined by establishing an ‘applicable amount’ (formerly called a ‘needs allowance’) and gradually reducing the amount payable as income goes up. Currently the taper is 20p in the pound, but because it comes off net income after tax and National Insurance, the amount reduced is unlikely to be exactly 20%.
62. Because CTR depends on an independent assessment of income, there is an interaction with other benefits. In the past, Council Tax Benefit was calculated and administered in tandem with Housing Benefit. The 20% taper of Council Tax combined with the 65% taper of Housing Benefit to produce an 85% taper. This is still the case after the separation of the benefits, but the proposals for Universal Credit will mean that the equivalent of Housing Benefit will be calculated together with Tax Credits, and CTR will then withdraw 20% of the remainder. It has been calculated that this change in the process will have the unanticipated consequence of leading to a significant reduction in entitlement to CTR.55 "I cannot understand", Les Robertson told the Committee, "why Council Tax Reduction was not taken into Universal Credit."56
63. The taper creates two problems. The first is that it is difficult for a claimant to tell how much they are entitled to, or, if their income goes up, when their entitlement will stop. The second problem is that people on low incomes lose much of the benefit of an increase in earnings. The UK Government’s welfare reforms have tried to limit the ‘poverty trap’, but the combined effect of withdrawing tax, national insurance, tax credits, Housing Benefit and CTR as income increases may leave little advantage in moderate increases in earnings. Jacqui Kopel, of Dundee Council, commented that—
"In terms of the taper and the in-work claims, it is difficult to say, but we are still finding it difficult to collect from those who are in work and to get them to pay more because of the level of their income."57
64. Advocates for means-tested benefits see the process of selectivity as ensuring that public money is targeted on those with the lowest incomes.58 However, the process is subject to inefficiencies—
- means tests are administratively cumbersome;
- they lead to inequities. A tapered scheme, which allows higher entitlement for greater liabilities, might give more assistance to people on higher incomes than on lower incomes;
- they fail to reach people who are entitled to them. Some 40% of those entitled to Council Tax Benefit in 2012-13 did not receive it;59
- the nature of Scotland’s labour market poses particular problems in dealing with people whose circumstances and incomes change rapidly. Fluctuating incomes present one of the main administrative challenges for both CTR and Housing Benefit.
65. The structure of CTR leads to problems of low take-up, uncertainty and delay. A report from Citizens Advice Scotland in 2005 pointed to these difficulties in Council Tax Benefit;60 CTR has the same design and administration. As the situation stands in Scotland, all claimants of CTR are liable to pay something towards Council Tax, because of the status of water and sewerage charges, which are collected by councils as part of payment of council tax but not relieved by CTR. This has implications for the recovery of debts. Defaults in Council Tax payment are subject to standard recovery procedures, which may lead to defaulters incurring court fees.
66. CTR is not the only way of reducing liability for Council Tax. 948,000 properties - over 39% of domestic properties occupied in Scotland - have a 25% reduction in liability because they are occupied by a single adult. A further 67,300 properties have an ‘occupied exemption’, which means that although the properties are occupied, no council tax is payable.61 The exemption is given to the property, not to the residents, so it is not a social security benefit. The main categories of property which are exempted are occupied by—
- non-British spouses and dependents of students;
- households headed by persons of 18 or under;
- armed forces personnel and their families;
- households where all the occupants are severely mentally impaired (the test has been problematic, and it may be a deterrent); and
- annexes used for a person in need of care.
67. One of the alternatives open to the Scottish Parliament is to change the scope of the exemptions rather than relying on the CTR scheme. An example might be to offer occupied exemptions to people with severe disabilities, e.g., those receiving the higher rate care component of Personal Independence Payment. However, as councils receive no subsidy for occupied exemptions (by contrast with CTR) they would need replacement funding.
68. Witnesses felt that Council Tax Benefit had worked fairly well. Dr Kenway, of New Policy Institute argued that the Council Tax Benefit Scheme introduced by the Major government was successful—
"It restored the credibility of the Council Tax and pushed up collection levels. We did not get rid of Council Tax Benefit because it was broken—that is clear—so, if we want a good scheme, there is the one that was introduced 20 years ago, which was quite good and has stood the test of time."62
The administration of Council Tax Reduction
69. CTR is similar in design and operation to Housing Benefit. There have been important variations in rules, but for more than 40 years the basic principles governing these benefits have been similar. The benefits have been operated together with Housing Benefit for much of the last forty years, and they have similarities in their operation and practical administration. The witnesses from local authorities all emphasised the efficiency and effectiveness of this system.
70. The separation of CTR and Housing Benefit has some important practical implications. The two schemes were able to operate by working from the same information and forms. Les Robertson of Fife Council and IRRVS commented—
"The way in which we administer housing benefit and council tax reduction together is very efficient. We get the information once and use it twice. Obviously that system is going to be disaggregated. I will give some figures. My current case load for housing benefit is 34,000, and I have just under 40,000 council tax reduction cases. ... we get funding to administer Housing Benefit. When we move to universal credit, that funding will be removed. ... I will be left with 40,000 council tax reduction cases to administer with no funding to deal with the housing benefit element. Someone will have to pay for that."63
71. Claimants for Housing Benefit now have to be directed to claim CTR separately; some fail to do so. Information from the DWP relating to Housing Benefit claims is not available for the assessment of claims that are only for CTR. Jacqui Kopel, of Dundee City Council explained that CTR—
"Was joined with housing benefit in previous years and we could use the information from the DWP. Because we cannot use that information now, we have to chase claimants to get them to apply for their council tax reduction ... The task has ... always been done for people alongside their housing benefit, but it is now separate and they are finding it more difficult."64
This problem will be exacerbated by the introduction of Universal Credit.
72. The Committee recommends that the Scottish Government should ask the UK Government whether the scheme can continue to be operated in tandem with Housing Benefit. The Committee will also write to the UK Government to raise the issue.
73. Another problem from the separation of the systems is that discretion is no longer available. Until April 2013, Discretionary Housing Payments were available both for Housing Benefit and for CTB. They have been discontinued for CTR. Susan Mathers of Falkirk Council commented—
"Prior to 2013, DHP was paid for council tax in very few cases. However, if localisation is to be introduced it will be an important mitigating tool, especially if there is to be protection for pensioners ... If localisation is to be brought in and funding cuts are to be passed on, there needs to be a mitigating tool, which would be a discretionary scheme."65
74. There is the need for some discretion to deal with vulnerabilities. Jacqui Kopel of Dundee City Council commented—
"Obviously we do not have the luxury of being able to make any such payments now, but as things change and people fall further into poverty because of welfare reform, a discretionary fund for council tax reduction would be welcome."66
75. The Committee would welcome further information from the Scottish Government on any discussions it has had with COSLA on introducing a protective discretionary element into the scheme.
76. From the perspective of local authorities, CTR and exemptions are issues of revenue as well as benefit. The CTR scheme is complicated by issues of assessing fluctuating incomes; taking evidence of income from self-employment, coping with varied deductions for non-dependants or chasing liabilities for water rates. At times councils are attempting to collect small amounts of council tax and water rates from householders on a very low income who have little means of paying. Les Robertson of Fife Council and IRRVS commented—
"the reason why in-year collection rates for council tax payments are at about 95 per cent is that some people really cannot afford it ... We know for a fact that people who are on benefit do not pay their water charges. That is probably not because they do not want to pay those charges, but because they cannot afford to pay them."67
77. There are concerns that the reforms are liable to increase the costs of administration, and that those costs will not be met by government. There need to be new systems and new IT. Susan Mathers, of Falkirk Council noted—
"The DWP is cutting the grant year on year. I know that for next year it is passing part of that grant over to the Scottish Government to distribute to local authorities. That is not reflecting the real costs that local authorities are bearing in administering the scheme even as it stands now—far less with any changes ... The impacts on customers will be duplication of effort, increased bureaucracy and lack of transparency."68
78. Several witnesses expressed concern about the impact of cuts and pressure on their staff and volunteers. Jacqui Kopel of Dundee City Council argued—
"Dealing day in, day out with people who find themselves in situations of severe poverty that they have never found themselves in before and hearing their tales of woe is having an adverse effect on our staff, because they simply cannot help them."69
79. Peter Kelly, of the Poverty Alliance, commented that staff in helping agencies are concerned—
"Not just about an increased workload and busier phone lines, but about having to give far more intense emotional support to their clients, which is an additional source of stress for staff in many organisation [...] people are doing better-off calculations for themselves and finding that they are not that far away from some of the so-called clients whom they are trying to help."70
80. In relation to Council Tax Reduction, the Committee commends the actions of the Scottish Government in protecting the vulnerable and recommends that the scheme be continued.
81. The elements of the budget relating to the mitigation of welfare reform are highly significant. Paul Drury, of Bethany Christian Trust, explained—
“My organisation works with those who are perhaps the most poor and marginalised and subsequently the most vulnerable: those who are homeless and formerly homeless ... as well as the financial impact and the consequent insecurity and uncertainty, we are noticing a real impact on the health—particularly the mental health—of the individuals that we are working with. They are saying to us, 'The major issue for me is not just the money worries but that my health is being severely impacted now.' That is a really notable part of the life that many of our service users are living now, due to the level of uncertainty and financial peril."71
82. Ruchir Shah, of SCVO, welcomed the expenditure—
"We welcome those provisions, which are a great recognition by the Scottish Government—and the Scottish Parliament more generally—of the intense need that is arising as a result of not just austerity or recession but the welfare changes that have come on top of that."72
83. The Committee received evidence from witnesses who had made studies of what has been happening in England, where there is no authority equivalent to the Scottish Government, capable of intervening to protect local authorities and citizens from some of the financial constraints. Phillip Edwards, of the University of Durham, explained in relation to the Scottish Welfare Fund that—
"The situation in English local authorities is totally different. The fund, as it is devolved to English authorities, is not ring fenced and there is no obligation to follow a set scheme. There is no overall general guidance, and there is a different social fund replacement scheme in each local authority.73
“There are no cash payments whatsoever in the north-east of England. Crisis support is all in-kind support, vouchers or, in one case, food packages. Such support is therefore not very attractive or common."74
84. In relation to Council Tax Reduction, English local authorities have been required to accept both the financial burdens of arranging support and a high level of risk. Some have been able to protect service users, but many have passed on elements of those risks to people on very low incomes. This situation has largely been averted by the Scottish Government's action.
85. The measures that are taken make a contribution to the Scottish Government's National Performance Framework. The principal contribution is not, however, to the aspiration that "We have tackled the significant inequalities in Scottish society”. The Deputy First Minister's evidence to the Committee was frank—
"The Scottish Government can do only so much and is doing as much as it can to mitigate the impact of such reforms ... The £4.5 billion figure that I mentioned earlier is the estimated impact on the economy over the five years to 2014-15. That is not only a massive sum of money, but a massive proportion of the total Scottish budget, and the idea that we can take away all the impacts of welfare reform is just not credible."75
The point was reinforced by Peter Kelly, of the Poverty Alliance—
“What we have seen is, in many ways, a necessary response to a situation that is in fact bigger than the level of response that we are able to give.”76
86. It is not realistic within the prevailing economic climate to hope to avoid any increase in poverty, or to reverse the direction of movement altogether. The objective of policy for welfare reform is to mitigate some of the harm that is being done by denying resources to the poor and most vulnerable. That aim does have implications for equality, but it is better described in terms of solidarity, described in the National Performance Framework as a 'higher level' objective. Solidarity is understood in the European Union as encapsulating the principle of mutual social responsibility; it has its strongest expression in systems of social protection and inclusion.77The same principle has been promoted in Scotland as part of the idea of the Common Weal.78 It implies a commitment to share burdens and risks, and to protect the vulnerable. That is what is expressed in the commitment to mitigation.
87. Concerns have however been expressed about whether current arrangements are sustainable. The SWF is being put on a statutory basis, but its real resource is set to decline. The cost of CTR is borne by local authorities as well as the Scottish Government, and concern has been expressed by the local authorities that the current arrangements may not be affordable. Sarah Flavell, of Gordon Rural Action pointed to particular uncertainty in the funding of advice services—
"We cannot afford to pay any more staff ...we have so many different batches of funding — for example, our money advisers are funded by Money Advice Scotland and welfare rights advisers are funded from elsewhere. At present, we do not even know how much money we will be getting from the council in six months, because it cannot say. I am not blaming the council - it obviously has to review its spending - but it is not able to tell us how much we will get, so we cannot guarantee that any of our staff will have a job in six months."79
88. Ruchir Shah of SCVO argued we need to recognise, that—
"Many of those provisions are short term and temporary. Most of them do not have sustainability built into them for the future but are for one year or two years."80
Value for money
89. Both the schemes scrutinised in detail here are relatively new, and the SWF in particular is working to newly developed criteria. It is difficult to establish value for money firmly. The rules and practice are still being developed; the information returned needs to be full and specific about the categories of help offered; the relationship of cash benefits to other forms of support needs to be examined thoroughly. Despite the gaps, however, there are already strong indications that the difference (or added value) obtained by the investment of £9.2m in the Scottish Welfare Fund by the Scottish Government has proved to be a major defence of the position of the poorest and most vulnerable people in Scottish society. This is seen by contrast with the position in England, where the lack of an equivalent resource has led to piecemeal, inadequate provision. The SWF makes a major contribution to social protection and the mitigation of harm.
90. The effect of intervention in CTR has been both to mitigate the effects on people on low incomes, and to avoid the transfer of liabilities to the poorest people that has been occurring in other parts of the United Kingdom. The scheme makes a valuable contribution to the incomes and liabilities of people on very low incomes, and it has avoided many of the problems that have become apparent in England, where burdens have been transferred to people with a very limited ability to pay.
91. The programmes under consideration cannot be assessed solely in terms of identified outputs or outcomes. In so far as the aim of the programmes is to mitigate potential harms, the objectives are preventative, and the test is what does not then happen that might have happened, rather than what does. Beyond that, the purpose of several of these programmes, the provision of advice of support and the SWF in particular, is also to provide social protection - support for when other systems fail, a safety net intended to be available in the event of crisis, emergency and otherwise unforeseen circumstances. The test of such a system is not that it should provide a set amount of money to specific, identifiable groups of recipients. The most important issue is that there should be such a system in place. Ideally neither discretionary assistance nor reactive support should need to be used extensively, because excessive reliance on such funding is an indication of inadequate provision elsewhere. The criteria used to determine whether the system is effective relate to coverage, accessibility and the security it provides. Further information will be needed to confirm that the policies are achieving their potential, and to monitor their progress, but the limited evidence we have received is highly supportive of the aims and operation of these systems.
92. The Equal Opportunities Committee has requested that we identify the implications of budget decisions for equality groups. The level of detail available for the operation of various mitigation measures does not make it possible to identify outcomes for different groups specifically. The SWF and CTR have been in place only since April. Although there is already some valuable information available on operations, including numbers, amounts and proportions, the returns do not classify recipients according to age, gender, disability or other personal characteristics. In principle, however, it should be possible to say something about the direction of movement, subject to qualification as information improves.
93. The process of mitigating welfare reform, and cuts in particular, offers benefits to those who are poorest, most vulnerable and most disadvantaged. The extension of advice services offers a sub-structure to a wide range of people, primarily those on low incomes. The abolition of the Social Fund affects a relatively small number of people, who stand particularly in need because of their vulnerability and lack of resource. The replacement of the system with the SWF offers a protection not otherwise available in equivalent English local authorities. From the known proportions of people who receive relevant benefits, this will include —
- older people, in relation to advice services and Community Care Grants;
- adults with disabilities, who are most welfare recipients below retirement age;
- people with mental health problems; and
- people on low incomes and low wages.
94. The provision of services to these groups will have a redistributive effect, and the effect of guidance is to direct resources to those people within each group who have low material resources. That implies a high level of vertical redistribution. However, given the fluctuating and unpredictable incomes of many people in the lower parts of the income distribution, and the insecurity of incomes among those who are earning, it is not possible to say with confidence that resources necessarily go to people in the lowest quintile of income, or even the lowest two quintiles.
95. This is also subject to the reservation made before in paragraph 90. The primary test of the effectiveness of many of these programmes, including the SWF, advice services and Discretionary Housing Payments, is not that specific groups receive specific amounts of money, but that there is in place a protective system that is available to protect citizens and mitigate harms. By putting an effective safety net in place, the Scottish Government and local authorities working in collaboration have avoided some of the evident harm that is being experienced in other parts of the UK. The Committee will continue to explore the equality impact of welfare reform in future ‘Your Say’ evidence sessions where it will hear from those who have been directly affected by welfare reform.
96. The Committee’s consideration of the draft budget this year has focused on the scrutiny of two new schemes introduced by the Scottish Government, the Scottish Welfare Fund and Council Tax Reduction. The Committee welcomes the introduction of both of the schemes and the actions being taken to protect the vulnerable.
97. As the schemes are new the Committee will continue to monitor closely the spending and operation of SWF and CTR. In relation to the SWF the Committee’s work on the interim SWF will be used to inform the Committee’s future scrutiny of the permanent scheme.
ANNEXE A: EXTRACTS FROM THE MINUTES OF THE WELFARE REFROM COMMITTEE
11th Meeting, 2013 (Session 4)
Tuesday 11 June 2013
Draft Budget Scrutiny 2014-15: The Committee considered and agreed its approach to the scrutiny of the Scottish Government's Draft Budget 2014-15.
The Committee agreed the Adviser Specification and to delegate authority to the Convener and Deputy Convener to consider a shortlist of advisers and rank in order of preference.
12th Meeting, 2013 (Session 4)
Tuesday 10 September 2013
2. Decisions on taking business in private: The Committee agreed to take items 7 & 8 in private. The Committee agreed its consideration of evidence received on the Scottish Government's Draft Budget 2014-15 should be taken in private at future meetings. The Committee agreed its consideration of a draft report on the Scottish Government's Draft Budget 2014-15 should be taken in private at future meetings.
7. Draft Budget Scrutiny 2014-15: The Committee agreed to delegate to the Convener responsibility for arranging for the SPCB to pay, under Rule 12.4.3, any expenses of witnesses on the scrutiny of the Draft Budget.
8. Draft Budget Scrutiny 2014-15: The Committee considered and agreed its approach to the scrutiny of the Scottish Government's Draft Budget 2014-15. The agreed to hold two evidence sessions, one each on the Scottish Welfare Fund and on Council Tax Reduction and on the witnesses.
13th Meeting, 2013 (Session 4)
Tuesday 24 September 2013
Draft Budget Scrutiny 2014-15: The Committee took evidence on the Scottish
Government's Draft Budget 2014-15, in round-table format, from—
Ruchir Shah, Policy Manager, SCVO;
Peter Kenway, Director, New Policy Institute;
Susan Mathers, Depute Chief Finance Officer (Revenues and Benefits), Falkirk Council;
Jacqui Kopel, Council Tax and Benefits Manager, Dundee City Council;
Paul Drury, Director of Income Generation and Development, Bethany Christian Trust;
Sarah Flavell, Director (Chair) and Benefits Advisor, Gordon Rural Action;
Peter Kelly, Director, Poverty Alliance;
Les Robertson, Institute of Revenues, Rating & Valuation and (Service Manager - Revenues) Fife Council.
Consideration of Draft Budget Scrutiny 2014-15 (in private): The Committee considered evidence received to date on the Scottish Government's Draft Budget 2014-15.
15th Meeting, 2013 (Session 4)
Tuesday 8 October 2013
Draft Budget Scrutiny 2014-15: The Committee took evidence on the Scottish Government's Draft Budget 2014-15 from—
Beth Reid, Policy Officer, Citizens Advice Scotland;
Phillip Edwards, Strategy and Implementation Director, Institute for Governance;
Douglas Proudfoot, Local Government Development Manager, and Anil Gupta, Chief Officer - Communities, CoSLA;
Andrew Hall, Revenues and Benefits Team Leader, Shetland Islands Council;
John Campbell, Service Manager Financial Inclusion, North Lanarkshire Council;
Nicola Sturgeon, Deputy First Minster and Cabinet Secretary for Infrastructure, Investment and Cities, Ann McVie, Team Leader, Welfare Division, Jenny Brough, Team Leader, Council Tax Unit, and Jamie MacDougall, Head of Housing Transitions and Support Division, Scottish Government.
Deputy First Minister agreed to provide the Committee with further written information on the changes to the Scottish Government's Scottish Welfare Fund guidance.
17th Meeting, 2013 (Session 4)
Tuesday 5 November 2013
Draft Budget Scrutiny 2014-15 (in private): The Committee considered a draft report to the Finance Committee on the Scottish Government's Draft Budget 2014-15.
18th Meeting, 2013 (Session 4)
Tuesday 12 November 2013
Draft Budget Scrutiny 2014-15 (in private): The Committee considered and agreed a draft report to the Finance Committee on the Scottish Government's Draft Budget 2014-15.
ANNEXE B: ORAL EVIDENCE AND ASSOCIATED WRITTEN EVIDENCE
13th Meeting, 2013 (Session 4), Tuesday 24 September 2013
New Policy Institute
Dundee City Council
Gordon Rural Action
15th Meeting, 2013 (Session 4), Tuesday 8 October 2013
Letter to Michael McMahon from Nicola Sturgeon regarding figures for Scottish Welfare Fund – 22 September 2013
Letter to Michael McMahon from Nicola Sturgeon regarding changes to Scottish Welfare Fund Guidance – 13 October 2013
Citizens Advice Scotland
Institute for Governance
Shetland Islands Council
North Lanarkshire Council
Supplementary Written Evidence
Letter to Michael McMahon from Nicola Sturgeon regarding additional Scottish Government funding – 18 October 2013
ANNEXE C: CORRESPONDENCE FROM COMMITTEE TO OTHER SUBJECT COMMITTEES
Letter from Michael McMahon to Conveners of Subject Committees regarding scrutiny of the Scottish Government’s Draft Budget 2014-15
2 The Scottish Government’s announcement of a further £20m 2014-15 was made after the Committee had concluded its oral evidence sessions on the Scottish Governments Draft Budget. The Committee received a letter from the Cabinet Secretary on 18 October advising the Committee that up to £20 million would be made available in 2014-15 to enable Local Authorities, for a second consecutive year, to top up their Discretionary Housing Payment budgets to the maximum permitted under UK legislation.
4 Scottish Parliament Official Report, 8 November 2012, Col 13215-13216.
5 Scottish Government. (2013) Scottish Budget Draft Budget 2014-15. Pages 8, 124, 125 and 140.
6 Scottish Government. (2013) Scottish Budget Draft Budget 2014-15. In table 9.11, and in the subtotal of £45.2 m on pages 120 (as £45m), 125, 140 and 185, and subsequent budget tables.
7 Scottish Government. (June 2013) Welfare Mitigation: The Scottish Government Response. Available at: http://www.scotland.gov.uk/Resource/0042/00426512.doc, Page 4.
8 Scottish Parliament Welfare Reform Committee. Official Report, 8 October 2013, Col 995.
10 Letter from the Deputy First Minister 22 September 2013
11 Scottish Parliament Welfare Reform Committee. Official Report, 8 October 2013, Col 992.
16 Scottish Government. (October 2013) The Scottish Welfare Fund: Guidance, updated post implementation, Section 5.
17 Scottish Government. (October 2013) The Scottish Welfare Fund: Guidance, updated post implementation, para 3.1.
18 Scottish Government. (October 2013) The Scottish Welfare Fund: Guidance, updated post implementation. para 3.3
19 Scottish Government. (October 2013) The Scottish Welfare Fund: Guidance, updated post implementation. para 6.1
20 Scottish Government. (October 2013) The Scottish Welfare Fund: Guidance, updated post implementation. para 6.9
21 Scottish Government. (October 2013) The Scottish Welfare Fund: Guidance, updated post implementation. para 6.2
22 Scottish Government. (October 2013) The Scottish Welfare Fund: Guidance, updated post implementation. para 6.8
23 Scottish Government. (October 2013) The Scottish Welfare Fund: Guidance, updated post implementation. para 6.10
24 Scottish Parliament Welfare Reform Committee. Official Report, 8 October 2013, Col 969-970.
25 Scottish Parliament Welfare Reform Committee. Official Report, 8 October 2013, Col 986-987.
26 Scottish Parliament Welfare Reform Committee. Official Report, 8 October 2013, Col 960.
27 Scottish Parliament Welfare Reform Committee. Official Report, 8 October 2013, Col 975.
28 Scottish Parliament Welfare Reform Committee. Official Report, 8 October 2013, Col 963.
29 Letter from the Deputy First Minister 22 September 2013.
30 Scottish Parliament Welfare Reform Committee. Official Report, 8 October 2013, Col 965.
32 M Jackson, B Valencia. (1979) Financial aid through social work, Henley: Routledge and Kegan Paul., page 112-114.
33 Social Work (Scotland) Act 1968, s.12(4).
34 Scottish Parliament Welfare Reform Committee. Official Report, 8 October 2013, Col 972.
35 Scottish Government. (October 2013) The Scottish Welfare Fund: Guidance, updated post implementation para 5.1
36 Scottish Government. (October 2013) The Scottish Welfare Fund: Guidance, updated post implementation para 3.1
37 Scottish Government. (October 2013) The Scottish Welfare Fund: Guidance, updated post implementation para 3.4
38 Scottish Parliament Welfare Reform Committee. Official Report, 8 October 2013, Col 964.
39 Scottish Parliament Welfare Reform Committee. Official Report, 8 October 2013, Col 970.
41 Scottish Government. (October 2013) The Scottish Welfare Fund: Guidance, updated post implementation, para 4.8.
42 Scottish Parliament Welfare Reform Committee. Official Report, 8 October 2013, Col 959.
43 Scottish Parliament Welfare Reform Committee. Official Report, 8 October 2013, Col 968.
44 Scottish Parliament Welfare Reform Committee. Official Report, 8 October 2013, Col 969.
45 Scottish Parliament Welfare Reform Committee. Official Report, 8 October 2013, Col 957.
46 Scottish Parliament Welfare Reform Committee. Official Report, 8 October 2013, Col 959.
47 S Bushe, P Kenway, H Aldridge, (2013) The impact of localising Council Tax Benefit, York: Joseph Rowntree Foundation.
48 S Adam, J Browne. (2012) Reforming Council Tax Benefit, London: IFS, page 29.
49 Scottish Parliament Welfare Reform Committee. Official Report, 24 September 2013, Col 959.
50 Dr Peter Kenway, New Policy Institute. Written submission.
51 Scottish Parliament Welfare Reform Committee. Official Report, 24 September 2013, Col 883.
52 Scottish Parliament Welfare Reform Committee. Official Report, 24 September 2013, Col 881.
53 Scottish Parliament Welfare Reform Committee. Official Report, 8 October 2013, Col 994.
54 Scottish Parliament Welfare Reform Committee. Official Report, 24 September 2013, Col 884.
56 Scottish Parliament Welfare Reform Committee. Official Report, 24 September 2013, Col 893.
57 Scottish Parliament Welfare Reform Committee. Official Report, 24 September 2013, Col 892.
58 e.g. P Whiteford, (1997) Targeting welfare: a comment, The Economic Record, 73(220), 45-50.
60 D McNeish, L Isaacs (2005) Council Tax, Edinburgh: CAS.
62 Scottish Parliament Welfare Reform Committee. Official Report, 24 September 2013, Col 885.
63 Scottish Parliament Welfare Reform Committee. Official Report, 24 September 2013, Col 895.
64 Scottish Parliament Welfare Reform Committee. Official Report, 24 September 2013, Col 894-895
65 Scottish Parliament Welfare Reform Committee. Official Report, 24 September 2013, Col 897.
66 Scottish Parliament Welfare Reform Committee. Official Report, 24 September 2013, Col 895.
67 Scottish Parliament Welfare Reform Committee. Official Report, 24 September 2013, Col 887.
68 Scottish Parliament Welfare Reform Committee. Official Report, 24 September 2013, Col 884.
69 Scottish Parliament Welfare Reform Committee. Official Report, 24 September 2013, Col 899.
70 Scottish Parliament Welfare Reform Committee. Official Report, 24 September 2013, Col 892.
71 Scottish Parliament Welfare Reform Committee. Official Report, 24 September 2013, Col 888.
72 Scottish Parliament Welfare Reform Committee. Official Report, 24 September 2013, Col 889.
73 Scottish Parliament Welfare Reform Committee. Official Report, 8 October 2013, Col 958.
74 Scottish Parliament Welfare Reform Committee. Official Report, 8 October 2013, Col 966.
75 Scottish Parliament Welfare Reform Committee. Official Report, 8 October 2013, Col 983.
76 Scottish Parliament Welfare Reform Committee. Official Report 24 September 2013, Col 983.
77 P Spicker (2006) Liberty equality fraternity, Bristol: Policy Press, part 3.
79 Scottish Parliament Welfare Reform Committee. Official Report 24 September 2013, Col 891.
80 Scottish Parliament Welfare Reform Committee. Official Report 24 September 2013, Col 889.
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