Publications

Citizens Advice Scotland (CAS) welcomes this opportunity to provide our overview of the impact of the Scottish Social Security landscape to inform scrutiny of this Bill proposing to amend the law governing the administration of social security in Scotland. As the amendments largely reflect our views expressed in the consultation process, including our recommendations, we have limited our response to those aspects of the Bill that are of the most direct concern to the Citizens Advice network in Scotland. We have expressed views where we believe there is scope for further amendments, or significant wrap around work needed to achieve the policy intent.

The last few years have been extraordinarily tough. The pandemic left 1.8 million people in Scotland financially worse off, and even before the most recent increase in the energy price cap one in three people found their bills unaffordable. Now people are faced with a perfect storm of soaring prices and flat or falling incomes, which risks sweeping tens of thousands of people across the country into poverty, problem debt, and destitution.

Those relying on the social security system are particularly vulnerable to poverty. Just over 447,500 people across Scotland are on UC – equivalent to more than one in ten working age adults in Scotland and almost double the number before the pandemic. Getting social security right is vital to help these people weather the storm.

Recent data from across the Citizens Advice network in Scotland shows the hardship people are facing every day:

• Advice need for food banks has grown by almost a third (31%) since September 2021.
• Advice need for other charitable support, including fuel bank referrals, saw a sharp increase of 23% between September 2021 and December 2021, likely reflecting the additional pressure of winter heating bills.
• Advice on UC sanctions has grown by 53% over 2021-22.
• Advice on UC Budgeting Advances has risen by 25% over 2021-22.
• Advice on UC Overpayments nearly doubled from the average across 2020/21 to Q4 of 2021/22.

Behind each of these statistics are real people. In this report we highlight four real Citizens Advice Bureau (CAB) client stories which show the incredible difficulties many people on UC are facing daily. Their names have been changed to protect their anonymity, but their stories demonstrate the reality of the cost of living crisis and the need for further support.

Key Points

• CAS is pleased to respond to this call for evidence on health assessments. We have long been calling for fairer processes which put people’s rights at the heart of it, and we want to see a fairer system of dignified, accessible, timely, and fair medical assessments that provide disabled people with the support they are entitled to.
• Although there will be no new claims for PIP due to the full implementation of Adult Disability Payment across Scotland from 29 August, we have responded to the questions relating to the future of PIP as we have a wealth of data and experience on the administration of PIP.
• CAS has restricted its responses to those where we have robust data to inform our responses.

Recommendations

• A range of assessment types should be available, face-to-face, telephone and in person, and the client should be able to choose their preferred method. Outcomes for each method should be monitored to ensure parity.
• Descriptors for both PIP and ESA should be reviewed to better reflect social and human rights models of disability and move beyond assessing a lack of functionality.
• The use of lived experience panels and user groups involved in the design and development of any changes made to the claims and assessment processes.
• Consideration should be given to the Social Security Scotland approach to assessment, in particular:
• The use of specialist assessors;
• Bringing the assessment 'in-house';
• Gathering evidence on behalf of the client; and
• Making a medical assessment the last resort.

This report, the last in a three-part series on UC during the pandemic, sets out what lessons can be learned from the past 18 months to future-proof UC. Updating and contextualising our survey with data drawn from the Citizens Advice network across Scotland, this report outlines the fixes that are needed for UC to properly support five groups of people who seek advice from CAB every day:

> People who are newly out of work
> People who are looking for work
> People who are in work
> People who are unable to work due to caring responsibilities or a disability
> People with children

Citizens Advice Scotland is calling for:

> Safe access to UC by introducing a non-repayable assessment period grant at the beginning of all UC claims and replacing the DWP’s debt recovery process with a revised system that better reflects people’s ability to pay
> A permanent increase to the basic allowance of UC
> A review of UC as an in-work benefit, including reintroduction of Work Allowances for everyone, to make sure UC properly supports those in employment
> Protecting and uprating support for people with disabilities and caring responsibilities
> Scrapping the benefit cap and the two-child limit

The Scottish Campaign on Rights to Social Security (SCoRSS) is a coalition of organisations who advocate for a reformed social security system that reflects the five principles set out in our Principles for Change. SCoRSS (previously the Scottish Campaign on Welfare Reform) encompasses over 40 organisations from key third sector organisations, charities, faith groups, and unions. Our members have a diverse range of experience and expertise and a strong understanding of social security and its impact on the people and communities we work with.

Focusing on the impact the £20-a-week cut to UC will have to Scotland, our briefing shows that:

• Nearly three quarters (74%) of Scottish Citizens Advice Bureau clients on UC will struggle if the cut goes through;
• 1 in 4 people claiming UC in Scotland say they are ‘very likely’ to need to skip meals when the cut hits, and 17% say they are very likely to use a food bank;
• As many as 4,000 low-income households (8,000 children) will lose entitlement to Scottish Child Payment if the cut goes ahead, due to the passporting of Scottish Child Payment from UC, meaning these families may face an income cut greater than £20-a-week; and
• More than half a billion pounds a year will be removed from the Scottish economy, cutting support for some of the most deprived parts of the UK.

SCoRSS is calling for the £20 weekly increase to Universal Credit to be made permanent.

The UK Government is proposing to cut Universal Credit by £20 a week from October 6th, reinstating it to pre-pandemic levels. CAS research shows that even with the increase, people on UC have struggled. Any cut will hurt people on UC and harm the government’s own Plan for Jobs and levelling up agenda.

CAS recommends cancelling the cut and permanently increasing UC’s basic allowance.

Citizens Advice Scotland (CAS) gathers evidence from the more than 171,000 clients a year supported by our network. Many of the problems faced by our clients are rooted in or linked to their incomes not being enough to meet their needs and live a dignified life. For many people coming to see us they simply do not have enough money to make ends meet: YouGov in May of this year indicated 1 in 7 Scots is struggling on their present income even with the temporary financial support measures put in place as a result of the pandemic. In fact, 56% or half a million pieces of advice provided by our network every year can be attributed to income maximisation. During the pandemic CABs unlocked £147million for people through things like social security payments, employment entitlements and lower bills for utilities. A Minimum Income Guarantee would mean the Citizens Advice network could ensure people have even more security and opportunity.

This evidence base, from over 80 years as Scotland’s largest free, impartial and confidential advice network, gives CAS a unique understanding of the issues that IPPR proposes could be addressed by a Minimum Income Guarantee. In addition, our experience supporting clients over the course of the pandemic shows that even those who were coping before the crisis still found themselves vulnerable if their income dropped or costs went up even slightly.

Between December 2020 and March 2021, the Scottish Government consulted on the first draft of new regulations for Adult Disability Payment (ADP). In June 2021, the Scottish Government published their response to this consultation. Citizens Advice Scotland welcomed encouraging signs in the latest government proposals, but CAS is calling for further change to get Adult Disability Payment right for disabled people in Scotland.

CAS supports in principle Scottish Ministers having the ability to suspend payment of disability assistance in certain prescribed circumstances, particularly when it would prevent a claim being closed altogether. CAS welcome the safeguards introduced and have one recommendation as to how safeguarding could be improved.

The absence provision to suspend can create particular difficulties for children whose parents separate, for example due to domestic violence, and the parent in receipt of the benefit is not the parent who has custody of the child. However, CAS hope this power will only be used in limited circumstances. CAS welcome that entitlement will be maintained in suspension cases prescribed.