CIH Scotland has welcomed the Scottish Government’s focus on creating a new social security system based on human rights, dignity and respect but has raised concerns about how the principles will be applied and measured.

In its submission to the social security committee’s call for evidence on the Social Security (Scotland) Bill, which was published in June, CIH Scotland said the devolution of social security powers “presents an opportunity for the Scottish Government to shape a system that better meets the needs and aspirations of the people of Scotland”.

But the housing body has also highlighted some concerns about how the performance of the new social security system will be monitored and reported on.

One of its reservations concerned the government’s plans to put most of the rules about the new benefits in regulations rather than in the Social Security Bill itself.

While CIH Scotland describes the move as “a sound objective”, it proposes that consideration should be given to the introduction of an independent body equivalent to the Social Security Advisory Committee (SSAC) for Scotland. Such a body, it argues, could advise on the content of regulations, which in many cases will require specific technical expertise, and help to ensure impartial and transparent review of and reporting on the operation of the new social security system as a whole.

The submission states: “It will be important to ensure that the expertise of those who work directly with the current system (such as welfare rights advisors) is taken into account during the drafting of the regulations as well as the experiences of service users. Frontline workers will be able to advise on aspects of the current system that could be improved and the how the new regulations are likely to work in practice and alongside reserved benefits.”

Welcoming the Scottish Government’s principles-based approach to social security, CIH Scotland said it hopes this will mark “the start of a culture change in Scotland and a move away from the negative rhetoric which has come to be associated with the UK welfare system in recent years”.

Despite this, CIH Scotland said it is unsure how the general principles will be interpreted, how they will be applied within the new system and how performance against these principles will be measured.

The submission states: “It is not clear how subjective terms such as ‘dignity’ and ‘respect’ will be measured, who will be responsible for ensuring that the principles are adhered to (Scottish Ministers, the new Social Security Agency or agency staff) and what the consequences will be of failing to meet them. Similarly, principle 7 states that the new system should be ‘efficient’. This could be interpreted as needing to drive down the cost of delivery or, on the other hand, needing to provide a quick and accessible service for members of the public. The intentions of the principles need to be clarified.”

It added: “Principle 5 states that the new system will be based on evidence. We welcome this approach but again, it is not clear what evidence it will be based on, who will be responsible for collating the evidence or testing the effectiveness of the system.”

CIH Scotland policy and practice manager, Ashley Campbell, told Scottish Housing News: “CIH Scotland supports the Scottish Government’s focus on creating a social security system based on human rights, dignity and respect. At the same time, these are subjective terms and more clarity is needed on how the performance of the new Scottish social security system will be measured against these criteria, who will be responsible for ensuring compliance and the consequences of failing to meet them.

“The Scottish Government intends to put most rules about those social security benefits being devolved into separate regulations rather than in the new Social Security Bill itself. We understand that this is intended to simplify the system and make future revision easier if this is needed. While we support this objective, we retain some concerns about the drafting and scrutiny of these regulations. To ensure proper independent scrutiny, we have suggested the creation of a Scottish Social Security Advisory Committee similar to the one which already exists at a UK level.”