Citizens Advice Scotland has responded to Ofgem's consultation on a debt relief scheme. The response highlights the huge demand for energy debt advice and makes recommendations about the scheme's design. 

The key points are:

• Ofgem should introduce a debt relief scheme urgently.
• Ofgem should engage the UK Government to obtain funding for an enduring debt relief scheme that supports people in energy debt after Ofgem’s proposed measures end.
• Ofgem should explore establishing a pre-approved level of support that allows organisations to build capacity before delivering the scheme.
• The scheme should include debt-matching and debt write-offs.
• We do not support Ofgem’s suggestion that only debt and arrears accrued between 1 April 2022 and 31 March 2024 should be eligible for relief.
• Setting a minimum level of indebtedness risks excluding people who need debt relief.
• Ofgem should use multiple affordability proxies. Using only Warm Home Discount presents particular problems in Scotland.
• Access to the scheme should not be conditional on making previous payments.

You can download and read the report below:

Social security continues to represent half of the advice work being undertaken by the Citizen's Advice network in Scotland. Universal Credit already represents one in three social security advice enquiries being handled by the network. The ongoing migration of people who are receiving older income-based social security payments to Universal Credit has been a very significant exercise and a milestone in the evolution of social security in the UK, while highlighting the urgency of change.  

This briefing presents insights into the impact the managed migration to Universal Credit process over the latest Quarter on the network and the people being supported by it.

Little is known about the impact of significant changes introduced in the last two years to the Administrative Earnings Threshold (AET). This second paper presents insights drawn from our unique advice provision data, reports from frontline advisers and two in depth telephone interviews with Universal Credit recipients.

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The coalition is calling for the following principles to underpin the 2025/26 Scottish budget

• Make respect for human rights and dignity the cornerstone of Scottish social security.
• Increase social security payment rates to a level where no one is left in poverty, and all have sufficient income to lead a dignified life.
• Financial security for women who experience domestic abuse
• Invest in independent advocacy and advice to help secure people’s right to social security
• Make crisis social security support work for Scotland

You can read more about ScoRSS and read its previous publications, including its vision for change post the 2024 General Election - Scottish Campaign on Rights to Social Security | CPAG

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Citizens Advice Scotland (CAS) supports the introduction of the Housing Bill to the Scottish Parliament and is keen to work with all parties to help the Bill realise its full potential.

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Ofgem recently consulted on refreshing its Consumer Vulnerability Strategy and CAS responded.

Key reflections on the Vulnerability Strategy

• There is no time to waste deliberating extensively over the definition of vulnerability – the priority of the regulator must be focused on tangible action to improve outcomes for consumers.
• Improved data collection needs a sector-wide agreement on what data is needed and a “one size fits all” approach to the data collected so it can be mapped across suppliers and sectors.
• The Strategy needs to go further in including debt write-off schemes by suppliers to mitigate for debt that can never be repaid. When debt is unavoidable and intractable, this indicates that the problem is rooted within markets and not within people at risk of or already experiencing vulnerability.
• A standardised approach to an inclusive and accessible service must be considered, specifically the Inclusive Service Kitemark, which is independently assessed and therefore can be more robustly enforced.
• Consumers, particularly those in vulnerable situations should be proactively involved in the development, design and delivery of innovations that support the transition to net zero.
• Consumer Vulnerability Panels should be further developed to ensure they are robust and fit for purpose. 

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Citizens Advice Scotland welcomes the opportunity to respond to the Scottish Government’s consultation on post school education and skills reform.

Integrating professionalised volunteering and voluntary organisations into the post-school education and skills reform is essential.

CAS recommendations for this piece of legislations are:

1. Visibility and Inclusion: Recognise the voluntary sector’s role in delivering skills outcomes within policy frameworks and funding models.
2. Funding Accessibility: Increase access to public funding for voluntary organisations to support their dual role in providing advice/advocacy increasing financial gain for clients and facilitating learning and development.
3. Accreditation and Recognition: Work with accrediting bodies to formally recognise training programs offered by voluntary organisations, thus validating the skills and competencies acquired through volunteering.
4. Policy Alignment: Align this new legislation with existing and forthcoming work on Community Wealth Building, National Performance Framework, and the Wellbeing Economy to ensure a cohesive approach to skills development and community empowerment.

Read the full consultation response below:

This submission incorporates feedback from the Citizens Advice network in Scotland, including our Extra Help Unit (EHU), to the Energy Crisis Commission. 

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Our key recommendations:

• Continued development and roll out of text message conveyed progress updates and an online progress tracker linked to a person’s online account.
• Clear and accessible communication to claimants at the outset that they may receive informal contact to clarify gaps in evidence will improve trust and efficiency. Advance notification of this contact via the appropriate communication channel (typically text message) will allow claimants to prepare, access support, and re-arrange the contact as required.
• Relationships between Social Security Scotland and the Third Sector could be further developed to establish consistent links between Local Area Delivery services and frontline advice and representation services. The creation of alternative routes to access Local Area Delivery services would optimise this potential.
• Recording assessment method (telephone, video, in person) combined with award type could help identify possible discrepancies in outcomes.
• Auditing of individual decisions and representative samples of decisions is necessary.
• The development of escalation routes to support advice provision while also building operational issue responsiveness and safeguarding capacity.
• To minimise the risk of claimants “falling through the cracks” a “safety net” provision for cases in which the functional test has not been satisfied should be developed, modelled on that used to determine work capability for means tested benefit.
• In the medium to longer term, anchoring ADP to its purpose to support people to break-down barriers to promote full participation in society and flourishing, requires a re-design of the criteria to better focus on how this can be achieved.

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