Citizens Advice Scotland (CAS) welcomes the general principles of the Bill which has the potential to create a new social security system that will make a positive difference for tens of thousands of Scotland’s citizens. There are, however, a number of areas that could be included on the face of the Bill as opposed to being left to regulations and guidance.
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The Bill should include a duty on Scottish Ministers to make provision for access to free, confidential and independent benefits advice.
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The system of redeterminations and appeals should be made one seamless process from the claimant’s perspective by the Agency passing the review decision directly to the Scottish Tribunals Service, rather than the claimant having to lodge an appeal themselves.
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Timescales for the re-determination process should be set out in the Bill, rather than in regulations.
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A CAS concern is that the Bill appears to make provision for overpayments as a result of an error by the Scottish Social Security Agency to be repaid by the claimant.
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The Bill should contain a common system for uprating the values of devolved benefits rather than determining the same through regulations.
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A common definition of residency should be added to the Bill.
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Given the level of detailed scrutiny of Regulations required, and the importance of these, CAS would recommend that an equivalent body (or bodies) to the existing UK Social Security Advisory Committee should be an essential feature of the new system.
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Whilst CAS agrees that the new social security system should offer the option of providing goods or cash, we would be supportive of clarification within the Bill that people will always be given a choice of cash payments, even if an in-kind option is offered.