Memorandum submitted by The Children's
Society (CS 37)
1. The Children's Society have been actively
involved in the establishment, workings and revision of the CSA.
As a national organisation serving the needs of children and young
people we welcome the proposed reforms and the child-centred spirit
in which they are made.
2. Although the White Paper has corrected many
of the inconsistencies in the Green Paper and is obviously the
result of wide and thorough consultation there are still outstanding
overall concerns. These include the continuing reliance on compulsion
to make the new system work and the resulting two tier system
of child support. We would hope that once the new system is operating
smoothly, the element of compulsion be removed, before considering
whether to introduce fees.
3. The formula: We agree that a simple
formula which enables parents to be clear from the outset on the
extent of their financial responsibility is likely to be perceived
as fair and will generate cooperation. We also agree that the
average amount should be lower than currently collected in order
to appeal to non-resident parents. Although it has an element
of rough justice, it appears to be the best compromise between
clarity and fairness.
4. Child maintenance premium: We welcome
the maintenance premium and believe it will provide a tangible
benefit to children as well as create a real incentive to cooperate
with the Agency. We are concerned about the uncertainty caused
to resident parents by irregular payments as well as the administrative
complications to the CSA. We would recommend the £10 premium
to be guaranteed by the CSA with the money recouped when payment
is made. This would provide a secure and regular payment to benefit
the poorest children and smooth the running of the new system.
5. Second families: It is essential to
a child-centred system that liability should be treated equally
for all children. For this reason we recommend the second option
presented in the Green Paper which calculates maintenance for
ALL the non resident parent's children and then splits it equally.
It is not clear how the new scheme can "show a slight preference
to children in the first family" and yet say `there will
be no `first class' and `second class' children in the second
family, when inevitably some of the children in the second family
will be the children of a first family for another resident parent.
6. Good cause: Whilst we see the advantages
in linking the Income Support claiming process with that for child
support, it must be made absolutely clear to the resident parent
that an Income Support application will trigger a child support
claim AND that the resident parent can pull out from the child
support claim if there is good cause. These would be the minimum
guarantees necessary to avoid parents not applying for Income
Support for fear of harm or undue distress as a result of a child
support claim.
7. Non cooperation is not a widespread problem
now, as shown by the Closer Working with the Benefits Agency.
This combined with the lack of evidence showing that the Reduced
Benefit Direction (RBD) has any effect on rates of compliance
with the CSA points to the need to abolish RBD. This penalty is
unfair to families on low incomes and works to the detriment of
their children.
8. Shared care: Whilst we agree with
the arrangements set out for shared care, it is still not clear
why daytime care cannot be included. In principle a full day spent
with a parent is as easy to establish as a night. Not to do so
discriminates against non resident parents on low incomes and
non resident parents with several children who cannot afford the
extra housing costs necessary for overnight stays.
9. Timetable of reform: We would argue
for the immediate implementation of specific reforms such as the
abolition of the reduced benefit penalty and the introduction
of the child maintenance premium, with other changes to be introduced
incrementally by the year 2001.
10. Collecting maintenance: We would
recommend maintenance to be deducted from benefits before any
other deductions. Given that only so many deductions can be made
from benefits before reaching the protected income level, it is
important that child maintenance be given first priority.
11. Promoting the reforms: Given the
loss of confidence in the existing child support system and its
poor success, we feel it is indispensable to actively promote
the new system as a radical overhaul with tangible incentives
for resident parents to cooperate in return for a service that
really does work.
12. Timetable of reform: We would argue
for the immediate implementation of specific reforms such as the
abolition of the reduced benefit penalty and the introduction
of the child maintenance premium, with other changes to be introduced
incrementally by the year 2001.
13. As a national childcare organisation working
with families and children in over 90 projects in England and
Wales, we are also very aware of the practical difficulties of
people's lives, the importance of providing an efficient and friendly
service as well as one that is integrated into other provisions
relating to families on benefits. Whilst the White paper may not
touch on them directly, we hope those concerns will be addressed.
September 1999
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