Response 986201377

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Individual
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Almond Housing Association
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44 Etive Walk
Livingston
West Lothian
Organisation/Group postcode**
EH54 5AB
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VIEWS ON POLICY ISSUES AND EQUALITY IMPACTS

1. Is it a problem that Local Authorities (LAs) use different ways to decide whether or not a Scottish Welfare Fund (SWF) applicant is on a low income to check that they are eligible for an award?

Please select one item
Yes
No
Please explain your answer.
This should not be a problem as long as applicants are treated the same regardless of which area they apply in.

2. What is the best way for an LA to decide that a SWF applicant is on a low income? Please tick one.

Please select one item
Option 1
Option 2
Option 3
Other - please give details.
Please tell us why you have chosen this option and explain the advantages and disadvantages.
The advantage to this option is that it leads to fairer decisions but still allows for variation for individual circumstances. The only disadvantage we could see is that the administrators of the Scottish Welfare Fund will need to continue to adapt to making more complex decisions.

3. What do you think the consequences would be if we limited crisis grant (CG) awards to three per household per year?

Each application should be decided on its own merit. By imposing a limit people in genuine need may be excluded. Instead the circumstances around repeat applications should be explored more to ensure there are no underlying problems.

4. What do you think the consequences would be if we limited community care grant (CCG) awards to three per household per year?

Setting a limit may penalise the most vulnerable and those in genuine need of items. Monitoring of repeat applications and the circumstances may be useful in establishing why these applications are being made.

5. Do you think that there should be a limit on the number of times that a CCG can be given for the same item in a set period?

Please select one item
Yes
No
If so, what should the limits be?
There should be limits for items that would be covered under warranties such as white goods for at least one year.

6. Do you agree that families facing exceptional pressure should be given priority in decisions on CG applications as well as CCGs?

Please select one item
Yes
No
Please explain your answer.
In many cases these families will likely fall under the category for those who are vulnerable so it makes sense to prioritise.

7. Which sorts of payment do you think are a cash equivalent that LAs should be able to use to pay SWF grants. You can choose as many as you like:

Please select all that apply
Paypoint or alternative electronic transfer
Allpay (without restrictions) or other loaded store card
Fuel Cards
High Street vouchers accepted at a number of outlets e.g for clothing
Travel tickets, bought on behalf of the applicant.
If there are other forms of payments that you think would be suitable cash equivalents for LAs to use, please tell us what they are.
N/A

8. How can LAs make sure that the way they are making the award ie in cash or by paying a cash equivalent, is the best one for the applicant?

There could be number of ways this could be done, applicant could be asked preference or it could be dependent on history of applications. If white goods are being supplied then it may be better to supply the item as it’s then guaranteed as new and prevents re-application due to breakdowns etc.

10. Do you agree with the draft statutory guidance on timescales for processing CGs. i.e. that:

Please select one item
Yes
No

10. Do you agree that substantial improvements to private property should be added to the list of excluded items at Annex A of the draft statutory guidance?

Please select one item
Yes
No

11. Do you agree that repatriation costs should be added to the list of excluded items at Annex A of the draft statutory guidance?

Please select one item
Yes
No

12. Do you think there should be any other items added to the list of excluded items in Annex A of the draft statutory guidance?

Please select one item
Yes
No

13. Do you think there should be any other items taken off the list of excluded items in Annex A of the draft statutory guidance?

Please select one item
Yes
No

14. Is there anything on the list of vulnerabilities at Annex C to the draft statutory guidance that you don’t think should be there?

Please select one item
Yes
No
If yes, please tell us what and explain why:
Repeated failed tenancies – on its own should not be seen as a vulnerability. More should be done to ensure tenants are being referred to support agencies to prevent re-occurrence.

A history of seasonal temporary or insecure work – should not be classed as a vulnerability, more should be done to ensure claimant is getting support to find long standing employment possibility of referral to local employment support agencies.

15. Is there anything that you think should be added to the list of vulnerabilities at Annex C to the draft statutory guidance?

Please select one item
Yes
No
If yes, please tell us what situation, condition or circumstance should be added to the list of vulnerabilities and explain why:
Relationship breakdown/separation - which would be seen to increase the vulnerability of the applicant.

16. What equalities impacts have you identified from the draft regulations and guidance attached at Annexes B and C to the consultation paper?

What equalities impacts have you identified from the draft regulations and guidance attached at Annexes B and C to the consultation paper?
By monitoring applications those who are underrepresented can be identified to ensure no one group is being prioritised over another.

VIEWS ON DRAFT REGULATION

17. Do you think that the draft regulations will have the effects that we have listed at section 2 of the consultation paper?

Please select one item
Yes
No

18. If you do not think that they will have these effects, please tell us about any gaps in the draft regulations at Annex B to the consultation paper or unintended consequences you would expect from these regulations:

If you do not think that they will have these effects, please tell us about any gaps in the draft regulations at Annex B to the consultation paper or unintended consequences you would expect from these regulations:
N/A

VIEWS ON DRAFT STATUTORY GUIDANCE

19. Please tell us about any concerns, comments or suggestions you have on the draft statutory guidance at Annex C to the consultation paper that are not already covered by the questions in Section 1 of the consultation paper:

N/A

VIEWS ON THE APPLICATION FORM

20. Should the application form for the permanent SWF be:

Please select one item
A combined CG and CCG application form
2 separate application forms
Please explain your answer:
There should be 2 forms as CGs should be easier and shorter to complete due to the nature of the claim and are unlikely to require the detail CCGs do

21. What information is collected on the application form for the interim SWF, at Annex D to the consultation paper, that you do not think is needed to assess an application?

N/A

22. How can the application form which is at Annex D to the consultation paper for the interim SWF be improved for the permanent SWF?

Pages 8-10 could be condensed as they all seem to be asking about income, could be shorter way of collating the information required.