The Child Poverty Action Group (CPAG) in Scotland works for the one in four children in Scotland growing up in poverty. We collect evidence from families living in poverty and campaign for solutions to bring about a society where children have a fair chance in life free from hardship. We provide training, advice and information on social security to frontline workers to make sure families get the financial support they need.
This is our response to a consultation that seeks views on the Scottish Government's vision and approach to ending the need for food banks as a primary response to food insecurity, and suggestions on what more can be done to shape a national plan.
1. Do you think that the approach outlined is consistent with the vision to end poverty and the need for food banks? Is there anything else you think should be included? No
In our 2021- 2026 Programme for Government , published before the May 2021 Scottish Elections, we called for the new Scottish government to end the need for food banks by 2026. We therefore welcome the Scottish government commitment to end the need for foodbanks, and believe the approach outlined in the consultation is at least in part consistent with this vision. As we said in our Programme for Government there is no shortage of food in Scotland and reliance on charity food aid highlights the extent to which tens of thousands of families continue to experience the stress, anguish and hardship associated with income crises. Whilst individuals and communities have stepped up and tried to plug the obvious gaps in our social security system with foodbanks and others forms of charity food provision, these are no alternative to the dignity and choice that comes with having enough money to buy food for yourself and your family. It is therefore vital that the government’s approach is clear that the aim is to end the need for all forms of charitable food aid.
The work of CPAG and our partners in the Menu for Change project has laid bare the triggers of food insecurity - inadequate and insecure incomes from work and social security. In order to end the need for foodbanks, and the food insecurity that drives that need, we need to reduce and prevent poverty. Much of the prevention work in the plan focusses on this.
We welcome the steps the Scottish Government has already taken, such as increasing investment in the Scottish child payment. These will have a real and significant impact on hard up families, reducing financial stress and the risk of the income crises that lead to reliance on foodbanks. However, to be consistent with the vision to end poverty and the need for foodbanks the draft plan must include further action to increase income adequacy and security. Our recommendations below (Q4) provide further suggestions that need to be put in place in order to reduce poverty and the number of people in food insecurity.
As well as having greater ambition this plan also needs to ensure that the actions already committed to are funded, and implemented, as a matter of utmost urgency. The Scottish government needs to ensure budget and policy decisions across government align with the vision and approach outlined in this plan. Families living in poverty cannot wait for support. We are seriously concerned, for example, that the commitment to extend free school meals to all P6 and P7 pupils by August 2022 – a key action to reduce the costs families face and support food security – has been delayed. We need to see more being done if we are to end food insecurity and ensure foodbanks do not become a permanent part of our society.
However even with increased, and immediate, preventative policies we will not sufficiently reduce the poverty level, nor sufficiently repair the social safety net, to immediately end food insecurity – particularly at a time when all households are facing additional pressures from the increase in the costs of living. Therefore, as the consultation paper recognises, there will is an immediate need to provide an effective, dignified and rights based response to food insecurity that is not foodbanks or other forms of charitable food aid.
We are concerned that some aspects of the response strategy are inconsistent with the aim of ending the need for charitable food aid.
For example, we do not see any place for the proposal to use shopping vouchers as a replacement to foodbank referrals within a strategic plan to reduce the need for foodbanks. Whilst an improvement on food parcels, they are not consistent with the ‘cash first’ approach the government is rightly committed to. Vouchers are less flexible than cash, create stigma and additional barriers and fail to respect individuals’ ability to make the best choices for themselves and their families.
We urge the government to look to how cash grants can be paid to those who need emergency support. Scottish welfare fund crisis grants could be used to provide a cash grant or, if someone is ineligible to support through the Scottish welfare fund, some other cash payment. For example, it is possible for Local Authorities to create additional financial supports, such as Argyll and Bute Council’s flexible food fund , if Scottish welfare fund payments are not, for some reason, available or suitable .
We can only end the need for charitable food provision in Scotland if we ensure everyone has enough money to afford the essentials for themselves and their families.
The work of Menu for Change has highlighted the role of the statutory Scottish welfare fund as an important source of crisis support. We believe that the Scottish welfare fund can play a greater role as a cash and rights based alternative to charitable food aid. The Menu for Change project and work with frontline children and families charities provides evidence of what needs to change in the operation of the Fund. These changes need to be put in place now, with adequate additional investment to support them, to better ensure a cash first response is available to those in acute food insecurity. Further details of how the Fund can to play this fuller role are outlined below.
We understand that some people, that face particular barriers to accessing statutory, local authority, or other mainstreams services, could benefit from direct provision via community organisations. The plan should focus on identifying which individuals and communities face such barriers and providing sufficient support whilst also addressing the barriers they face accessing statutory sources of support.
In relation to the response actions already underway we welcome the focus on promoting principles of dignified access to food and recognise the wider need to support the role that community food initiatives play in supporting public health and community development. Looking ahead however it is important to recognise that a truly dignified strategic approach to ending the need for foodbanks and other forms of charitable food aid must focus on ensuring people have access to the cash they need to buy food. The focus of the plan and associated funding needs to be consistent with a cash first approach, and on ensuring access to adequate income – not on food distribution.
2. Do you think that the actions underway will help to reduce the need for food banks as a primary response to food insecurity? Yes
3. Do you think that the suggestions for what more we plan to do will help to reduce the need for food banks as a primary response to food insecurity? Yes
4. Is there anything else that you think should be done with the powers we have at a national or local level to reduce the need for food banks as a primary response to food insecurity? [Open comment]
We welcome the fact that the ENFB draft national plan recognises that the main driver of food insecurity is 'insufficient and insecure incomes' and that much of the plan to prevent the need for foodbanks focuses on policy areas that increase incomes and reduce poverty. However, the Scottish government must do more in these areas if it is to successfully end the need for foodbanks, as well as meet its child poverty targets. Specifically it needs to focus on additional social security investment, embedding a ‘no wrong door’ approach across government and maximising income from employment.
On social security, we welcome the commitment to increase the Scottish child payment to £20 per week per child but realise this that is insufficient, in itself, to end the need for food banks, or to meet Scotland’s child poverty interim target. There needs to be additional further investment in social security for low-income households. Investment in social security is the key action that the Scottish Government can do to end the need for foodbanks. Whilst the bulk of the social security system is not within the Scottish Government’s control any meaningful plan to end the need for foodbanks requires the Scottish Government to use its social security powers to maximum effect to provide support for those to whom the UK social security’s provisions are inadequate.
Specifically the following additional investment is social security would have a significant impact on reducing the need for emergency food aid:
• Increase Scottish Child payment so that, whatever the impact of other policies, less than 18% of children are living in poverty by 2023/24;
• Roll out the Scottish child payment to eligible over 5s as soon as possible, and by the end of 2022 at the latest, and in meantime ensure that the ‘bridging payments ’ made to families not yet receiving Scottish child payment, are at the same level as the Scottish child payment i.e. £20 per week per child from April 2022
• Guarantee sufficient funds are available to local authorities to fully mitigate the UK social security benefit cap, as has been done in relation to the ‘bedroom tax’, and consider how the two child limit could be mitigated;
• Undertake a review of the Scottish child payment and its delivery mechanism. Take-up will be critical to achieving the policy intent and lessons from the initial roll out must be learnt in time to put in place any changes needed to both support ending the need for foodbanks, and to meet the target of less than 10% of children living in poverty by 2029/30;
• Increase the level of Best Start grant, and consider the evidence for making Best Start grant payments universal;
• Create a dedicated support fund or entitlements with clear guidance, capable of delivering short-term recurring payments to support people leaving an abusive partner; and
• Ensure local authorities receive sufficient funds and clear guidance to enable them to use local powers to provide payments to migrant families whose status limits their rights to social security benefits and who are at risk of destitution.
We welcome the forecast by the Scottish Fiscal Commission that the changes made to the processes for applying for, and assessing, entitlement to the new Scottish disability payments is expected to increase the number of successful applications for disability benefits by 21 per cent in the long term . Whilst not specifically a poverty reduction measure, we know that households affected by disability are more likely to live in poverty and therefore any additional help with the costs of having a disability will reduce the financial pressures on many families. In order for these intensions to be realised it is important that the Scottish Government provide sufficient budget to allow this investment in social security. Analysis should be done to understand the impact additional investment in disability benefits will have on reducing poverty and on ending the need for foodbanks.
‘No wrong door’ to social security and wider support
We welcome the commitment to strengthening partnership working between sectors and services. There needs to be a wider, cross governmental, policy to ensure a ‘no wrong door’ policy for anyone seeking financial support. Social security payments, and other supports, are provided by a wide range of different organisations and agencies. Scottish government and its partners should ensure that all frontline staff are appropriately trained, and that there are robust and fully funded referral networks established between the different agencies and partners delivering social security and other types of support, with data sharing where appropriate. This will remove the need for claimants to inherently know which benefits and support they may be entitled to and how to claim them.
• Susan is a lone parent of a disabled child, Euan
• Susan claims child benefit from HMRC and universal credit from DWP.
• Entitlement to universal credit means she can claim Scottish child payment from Social Security Scotland.
• She can also apply to the local authority for council tax reduction and for a discretionary housing payment to help with her rent
• She claims child disability payment from Social Security Scotland.
• Entitlement to child disability payment means that she can claim carer’s allowance from DWP. She should tell the universal credit section of DWP that she is receiving child disability payment and carer’s allowance so that additional elements are added to her universal credit.
• Entitlement to carer’s allowance means that she will also be entitled to carer’s allowance supplement from Social Security Scotland – she will not have to apply for this, as it is automatically paid to carers living in Scotland who are receiving carer’s allowance.
• An application needs to made to the local authority for free school meals and a school clothing grant
• An application to Social Security Scotland needs to be made to get Best Start Foods and, when the child reaches the eligible age for best start payments.
• As a household on a low income, with a disabled child, she may be entitled to help via Home Energy Scotland – but she will have to contact them to find out more.
Data could be shared between the Scottish agencies to ensure that Susan is aware of the different supports that are available, and so she knows she can get the help she needs to claim them. An active referral to an advice or support agency could assist her with her claims for benefits from UK agencies.
Maximising incomes in this way will reduce food insecurity.
Maximising income from employment
There is extensive evidence that poverty, gender and disability are inextricably linked. Analysis suggests that removing barriers to work for mothers and for parents affected by disability, and tackling the labour market inequality they face, is necessary to address child poverty . Existing action to focus employability support on removing barriers to work is very welcome and should, based on evaluation of what works, be scaled up so that it is readily accessible by all parents struggling on low incomes,
In addition, there need to be action to:
• review international and historic evidence on what employment interventions have made substantive impact on employment rates of parents – particularly women and those affected by disability - and levels of poverty, and identify the lessons for Scottish policy.
• produce guidance and good practice on the use of public procurement as a lever to drive improvements in job opportunities and quality of work for parents
• use public body wage setting powers to address low pay, particularly in female dominated sectors such as social care and child care;
• introduce greater conditionality for companies accessing public money with requirements for them to increase the quality of work they offer as well as improve the support they provide to those with caring responsibilities;
• build on the Gender Pay Gap Action Plan and ensure a gendered and poverty focussed approach to all labour market policymaking.
Despite progress, childcare provision across Scotland contains real gaps, particularly for older children, children with disabilities and where parents work atypical hours. There needs to be sufficient investment in childcare to ensure childcare policies contribute to reducing poverty by enhancing children’s experiences, removing barriers to work and improving wages and conditions of those who deliver the service.
Increase eligibility to free school meals
We welcome the Scottish Government’s expansion of free school meals to all primary school pupils. However, we are concerned that the commitment to expand free school meals to all primary children by August 2022 has now been delayed, and there is no clear commitment as to when the required capital and revenue spending will be provided to local authorities to fully roll out this policy. This delay does not seem consistent with the approach set out by the paper.
The Scottish government should ensure a healthy school meal is part of the school day for all secondary as well as primary pupils, in the first instance extending entitlement to all pupils in families in receipt of universal credit or equivalent legacy benefits . It will have a direct impact on families incomes, and therefore help prevent families falling into food insecurity, as well as ensure that those children in food insecurity are receiving at least one nutritious meal every day.
Scottish welfare fund
There needs to be a shared vision across national and local government and the organisations that support low income households of the part the Scottish welfare fund should play, as provider of cash support when people face a crisis or exceptional circumstances, in ending the need for foodbanks.
In order to achieve this, the strategy needs to clearly set out the role the Scottish welfare fund will play in ending the need for foodbanks.
We know from Menu for Change that when it works the Scottish welfare fund plays an effective role in preventing the need for food bank use . Yet we also know from our work and the work of our partners that many people facing the income crisis that precipitate the need to use a food banks are unaware of, or unable to access, cash support from the Scottish welfare fund.
Within the current Scottish welfare fund legislative framework, many of those that require emergency food aid may be eligible for support. However, the current level of investment in the Scottish welfare fund, and the administration of the scheme, does not appear sufficient to ensure the administrative capacity and allocated funding is adequate to maximise its potential to reduce the need for foodbanks.
With sufficient funding, refreshed guidance and a renewed vision of its role, the Scottish welfare fund could become a replacement for foodbanks for many more of those facing an income crisis.
However the current legislative framework does not allow the Scottish welfare fund to provide ongoing financial support, and therefore there needs to be alternative support for those in longer term food insecurity.
There are also groups of people, such as those with no recourse to public funds , who are currently unable to access the Scottish welfare fund. The Scottish government should ensure that there are equivalent financial supports available to those who are excluded from the Scottish welfare fund. We also support calls for the Scottish welfare fund to be made available for those with no recourse to public funds, to bring parity with the Welsh Assistance Fund. In the meantime there are other mechanisms that could be used to support those with no recourse to public funds – for example families with no recourse to public funds may be able to access the Scottish child payment bridging payments. Such mechanisms could be used to provide equivalent support – as long as this is provide in such a way as to not impact on claimants’ immigration status.
We welcome the announced review into the wider effectiveness of the Scottish welfare fund. However, to specifically reduce the need for foodbanks, changes to the scheme can be made, and the level of investment in the scheme increased, immediately.
As well as setting out the role the Scottish welfare fund can play in ending the need for food banks, the plan should include the following immediate actions to improve its operation :
• An audit of local authority websites to ensure Scottish welfare fund information is up-to-date, easy to find and easy to understand and available in a formats and languages that reflect the local authorities demographics. Evidence from our own work and that of organisations we work with is that information on some local authority websites is sometimes out of date, difficult to understand or incorrect. There is a lack of awareness of the Scottish welfare fund.
• Clear decision notices should be issued so that claimants understand why, if they have been refused an Scottish welfare fund award, the reasons for that refusal and are fully aware of their right of appeal ;
• The decision-making process and award amount should consider how long the financial crisis will last so that the award will adequately fill the gap until the emergency is over;
• Better training and support for decision makers to help ensure that guidance is followed in every case; from our evidence and recent SPSO review decisions we are aware that guidance is not always followed
• More effective communication of changes to Scottish welfare fund guidance by the Scottish Government to frontline workers ;
• A clear referral pathway to income maximisation, and debt advice, for anyone accessing the Scottish welfare fund with sufficiently resourced advice services to pick up such referrals; and
• Sufficient resources need to be invested into the administration of the Fund.
5. Do you have any views on how we intend to measure impact, and what would give you confidence that we are moving in the right direction? [Open comment]
As the principle cause of food insecurity is poverty, measuring reductions in poverty is a key element of ensure that these policies are having the intended impact.
Income-maximising solutions are needed to end the need for food banks. In-kind solutions, such as shopping vouchers, which de facto replace the use of a food bank, may not tackle the underlying need and risk conflating reducing use of food banks with genuinely ending the need for food banks.
6. Is there anything else that you think should be considered in the development of this plan?
There needs to be a strategy in place to ensure no-one is referred for emergency food without also being offered advice, and that other cash first options are considered before a referral to a foodbank is made.
Every local authority should have a strategy to ensure that all agencies that refer to foodbanks are supported to put robust processes in place to ensure that all other options are explored, including the Scottish welfare fund, before resorting to a foodbank referral. Furthermore the expectation should be for agencies to make active referrals to advice and support services, rather than simply signpost people in crisis.