COSLA Community Care Charging Guidance Consultation – Questions
Please type in your responses to the questions in the boxes below. The length of your response is not limited by the size of the boxes. Alternatively you may wish to print out the form and complete it by hand.
Organisation / Perth and Kinross Council
Contact Name / Colin Crawford
Telephone Number / 01738 476703
Email /
1. / Do you agree that the personal contribution to the cost of community care services should be based on the ability to pay?
See question 14.
Yes, however this does result in other challenges for Councils. It does make it far more expensive and bureaucratic to administer, and it is difficult to explain charges to service users. Although service users make a contribution, headline charges are always used as the focus by those challenging charges.
We should ensure consistency across Councils/public authorities to agree the full range of services which when charged are subject to “means testing”. Have one means test for a Council service user which covers a range of services/charges?
This would reduce the number of duplicate financial checks and calculations, improving the service users experience while reducing the bureaucracy/cost and also reducing the potential of placing people into financial poverty. At the moment this could include e.g. Council Tax, Housing Benefits, Free School Meals, Clothing Grants and Blue Badges.
The proposals laid down in the Welfare Reform Bill which are to take effect from 2013 could mean that Council Tax, the local/national scheme to replace Council Tax Benefit, the local/national scheme which is to replace the Discretionary Social Fund and other local/national schemes offered by the LA could all be administered together at the first point of contact.
2. / What would be the benefits of making charging regimes across local authorities more consistent?
It would reduce the local officer time spent consulting and implementing changes to charges with the community and press. A national group/partnership could arrange to share information and publicity campaign for Scotland giving a consistent message to communities. Another benefit would be for service users to have an understanding that all Councils would have similar charges for specific services. It would also depend on the level of discretion within the national policy was available.
3. / What are the advantages of having the flexibility to set charges locally?
The main advantage is maintaining local democracy, with local Councils empowered to make decisions for which they are accountable to the local community. It would also encourage continued consultation and discussion with service users in the community. It would also allow local charging policies and solutions which were aligned with local planning and strategies. One solution to fit all does not always give the best option for local communities. An option would be a local advisory group with input from the third sector and service-users which advises on the needs of people locally.
4. / Do you feel that there is a sufficient degree of transparency and inclusion regarding the development of COSLA’s NATIONAL charging guidance?
More transparency and inclusion in the development of the National charging guidance has been a feature in recent years; however until recently the NATIONAL charging guidance has not been reviewed with sufficient involvement from service users, carers, and voluntary groups.
5. / Do you feel that there is a sufficient degree of transparency and inclusion regarding the development of LOCAL charging policies?
We have our charging policy submitted and approved by Council Committee annually. We also have any new or revised charges approved as part of the budget setting each year. As part of the budget setting process we do undertake an impact and equality assessment; however we hope to continue to improve our practice. We also have clear and transparent guidance and leaflets for our citizens and service users. However, as we have introduced a wider range of services within our charging policy it has been a challenge to consult interested parties and service users within the process(due to the nature of charging and the political process.)
6. / What would be the impact of increasing charges to service users?
Our charging policy follows the national guidance and therefore we would hope that the impact of increasing charges would not have a detrimental financial impact which would cause financial hardship. The income raised would enable the Council to maintain or increase the level of services to those most vulnerable citizens in our communities.
However, the impact of increasing charges may have the hidden impact of deterring people from seeking appropriate preventative and essential care support. The impact may be that due to not receiving appropriate preventative care, additional more costly long term care and health costs will need to be borne by the public purse. How many people who may have been able to stay at home with minimal support have required hospital and long term residential care earlier due because they did not refer earlier? Will increased charges be a blockage which impacts on the outcomes and benefits hoped to be achieved by the Change Fund initiative?
Charging and increasing charges will also be a blockage, and hinder social care and health services working in an integrated way to deliver better outcomes.
Does charging hinder public services ability to reform public services, improve performance and reduce costs?
As charges are increased income maximisation checks undertaken will enable service users and their carers to claim additional benefit entitlements.
7. / What would be the impact of decreasing charges to service users?
This would place an immediate pressure on some Councils who have partly funded services from income generation. However, this would be reduced as the administration and “failure demand” in the system due to charging could be saved. There would also be a positive impact on the wellbeing of service users and their families from decreasing or even withdrawing charges.
Another negative impact on reducing charges is that Councils may receive an additional number of referrals requesting care.
Income maximisation is an important feature of social care charging and Councils must ensure that welfare benefit checks /income maximisation is not reduced.
8. / Do you agree that the COSLA guidance should be linked to DWP thresholds?
The COSLA guidance currently users the DWP thresholds which does keep consistency between the other public sector welfare assessments and community care. The use of the thresholds also offers consistency with the CRAG for Residential Charging.
However, it would be appropriate for the calculation of the threshold level to be set at a level which is agreed to be linked to the real cost of living for people living in the community. Independent research had identified the cost of living for an older person to be higher than the DWP rate. The % above the DWP rate should be reviewed when setting the threshold.
Capital limits and the notional income from capital need a full review instead of continuing to align to the DWP, especially as interest rates are very low which does not enable the notional income to be achieved.
9. / Should there be a standard format for charging information?
Until there is more consistency across Scotland this will be difficult to achieve. As Councils become more innovative in developing new care arrangements - and increase joint and integrated working with Health and other agencies – the ability to have transparent charges will become more difficult.
10. / Do the “reasonably practicable to pay” provisions in the 19681 Act protect people from being overcharged?
Yes – if a service user avails himself of a service provided under the Act and satisfies the authority providing the service that they have insufficient means for it to be reasonably practicable for them to pay for the service the amount which he would otherwise be obliged to pay for it.
11. / Should guidance on “disability related expenditure” be included as practiced by local authorities in England2?
Yes guidance should be included to assist local authorities on determining whether to include this in the financial assessment process to enable them to make a decision that is equitable and fair. The cost of living for those with a disability is generally higher i.e. higher fuel costs, higher travel costs, higher food bills and costs associated with other social and personal needs. The link between poverty and ill-health is well-documented and a robust charging policy should have a mechanism which gives the flexibility to allow for these additional living costs.
12. / How will the development of Self-directed support impact on charging regimes?
Service users will still be expected to make a contribution towards their care. The charging policy will be developed locally to ensure we continue to agree the package and the contribution that a service user will make towards that package. The Councils is still developing the arrangements as part of the development of personalised services.
13. / Do you believe that a system of benchmarking would deliver greater consistency across local authorities? If so, how should this be done?
Benchmarking would allow local authorities to review its charging policy and provide information to challenge the reasons for any differences. However, local authorities will have different service arrangements, definitions and costs therefore it is difficult to compare.
Due to the complexity of the charging policy and calculation, and the circumstance of each service user is different it is almost impossible to compare. The only way to enable a snap shot to be used for benchmarking would be to develop a number of scenarios for different service users.
14. / Are there any other issues and comments you wish to submit.
As part of our charging regime in Perth and Kinross we have offered income maximisation to our service users and achieved substantial levels of additional income for them. We would not wish to lose the “benefits” of income maximisation with any changes to charging.
The ability to develop a charging policy which is “ cost effective”, “transparent and simple to understand” and is “means tested” is almost impossible to achieve, however administering all LA services at one point could reduce overall costs and improve the customer’s/service-user’s. It may block future integration with health and other partners and result in more long term costs for the public purse COSLA should consider ceasing non residential charging. Could Councils/Government offer Bridging finance e.g. Change Funding to be used to allow Councils to recover the loss of income over a 2 or 3 year period.
£44million income was charged for non residential social work services in 2009/10 (using LFR return) by Scottish Councils. The funding required by Councils to cover the shortfall would be approximately £40million as administration costs would not be required in future. This would be substantially less than the annual cost to the Scottish Government of scrapping prescription charges which was estimated at £57million.
Please email your return to by Friday 9th September 2011. Alternatively post to Amanda Hogg, Health & Social Care Team, COSLA, Verity House, 19 Haymarket Yards, Edinburgh, EH12 5BH.
References.
1. Section 87(1A) of the Social Work (Scotland) Act 1968.
2. Fairer Charging Policies for Home Care and other non-residential Social Services (DoH September 2003).