Letter to organisations asking for views on the Council Tax Reduction (Scotland) Regulations 2021
Letter to Citizens Advice Scotland, CPAG, Inclusion Scotland, IRRV, One Parent Families Scotland and The Poverty Alliance, 23 August 2021
The Council Tax Reduction (Scotland) Regulations 2021 are due to be considered by the Committee on 23 September. These consolidate the existing regulations for working age council tax reduction and make significant changes to the way it is calculated for those in receipt of Universal Credit. They are expected to come into effect for financial year 2022/23.
The Scottish Government has also prepared a paper modelling the impact of the changes on different household types. A copy is attached. This sets out:
- Background to the CTR scheme, and why some households currently get different levels of CTR depending on whether they are getting Universal Credit or legacy benefits
- How the new scheme seeks to address this, and analysis of its impact on different households
- Micro-simulation modelling of the impact of the new rules across the whole caseload
As an organization with expert knowledge of the council tax reduction scheme the Committee is writing to ask your views on these regulations.
In particular:
- Have you been consulted by Scottish Government officials on these regulations? If so, do you have any comment on that engagement?
- Do you consider that the regulations meet the policy intent, set out in the policy note that: “as far as practicable, a household in the same circumstances receives the same level of Council Tax Reduction whether it is on Universal Credit or not.”
- The new rules aim to provide equity ‘as far as practicable’ but will not do so in every single circumstance. (See Scottish Government background paper sections 3.5 and 4). Have you identified situations where the new regulations will not provide the same level of CTR on Universal Credit as on legacy benefits and does this give you any concerns?
- Do you have any suggestions that would further reduce the occurrence of different levels of CTR support for those on Universal Credit compared to legacy benefits?
- Do you have any concerns about the changes to local authority systems that will be required as a result of the new rules in these regulations?
The Committee would appreciate written views by 13 September. It would also be helpful to know whether you would be willing to provide oral evidence if needed.
I appreciate this is a short timescale given the technicality and length of these regulations, but any assistance in the Committee’s scrutiny work would be much appreciated.
Yours sincerely
Neil Gray MSP
Convener, Social Justice and Social Security Committee