Select Committee on Work and Pensions Written Evidence

Supplementary memorandum submitted by One Parent Families



  1.  This note to the Committee expands on the earlier submission made by One Parent Families giving its initial response to the Government White Paper on child support.[5] We have sought both to reply in more detail to the specific questions asked in the White Paper and also to raise additional points and questions which we think need to be addressed—the question of shared care (paragraphs 58-61); the question of access to the Courts for parents with care to seek enforcement (paragraphs 65-67); the need for broad anti-avoidance measures (paragraph 55); the question of joint registration of births (paragraphs 79-81); and the question of a maintenance guarantee (paragraphs 82-89).

  2.  An initial observation is that more information is needed to properly assess the impact of the White Paper proposals and whether the new Commission will work in delivering more child maintenance to children in separated families. In particular, more information is needed concerning:

    —  the Government's working assumptions of the number of parents with care on benefit, who will choose not to continue to use the Agency/C-MEC once they are offered this choice and the expected caseload of the Commission compared to the CSA;

    —  the impact the new assessment formula will have on the child maintenance liabilities of non-resident parents, in terms of the proportion who will end up paying less or more compared to their current level of payment;

    —  the proportion of non-resident parents (both employed and self-employed) whose income changes significantly a) from year-to-year and b) in-year, and hence will be eligible for a re-assessment of their liability; and

    —  how the transition between Schemes 1 and 2 (the `old' and `new' schemes) and Scheme 3 will be managed, and what is meant, in practice, by a `clean break'.

Help tackle child poverty

  4.  The White Paper identifies tackling child poverty as "the first and most critical test for reform" (paragraph 1.29). One Parent Families agrees that tackling child poverty is a top priority. Child maintenance by its nature mainly benefits children in lone parent families. It is thus already focused on a group at particular risk of child poverty: their poverty risk is 48%, compared to 20% for children in couple families.[6] 95% of lone parents are receiving a benefit or tax credit (excluding child benefit).[7]

  5.  We would warn against narrowing the child poverty focus within child support to concentrate simply on children where the parent with care is receiving Income Support or income-related Jobseeker's Allowance. This would be to ignore the considerable importance of receipt of child maintenance to the 56.5% of lone parents in employment. A recent analysis of the 2004-05 Family Resources Survey showed that, where the lone parent was in employment, 27.1% of children were lifted out of poverty after child support was taken into account. This rose to 64.2% of children, if only lone parents actually receiving child support were included.[8] This has implications both for the target audience of the proposed package of information and guidance services on child maintenance (see below) and for the principles guiding the approach to managing the transition to the `new plus' system (see below)

  6.  To tackle child poverty, two main strategies are identified: to ensure that more parents pay child maintenance; and secondly, to ensure that children receive more of the value of what is paid.

Ensuring more parents pay child maintenance: abolition of Section 6 of the Child Support Act 2001

  7.  We support the proposal to abolish the requirement placed on parents with care to claim child support if claiming an out-of-work benefit. However, if the Government wants to increase the number of children in separated families for whom child maintenance is paid, the case for seeking child maintenance—by whatever means is most suitable—should be actively made to all lone parents whether in work or not, with advice and positive support to overcome any reservations they might have. At the same time, more needs to be done to positively engage with non-resident parents to persuade them that child maintenance matters for their children.

  8.  It is also important that the Government takes steps to actively monitor the impact of its proposed new policies to check whether it is being successful in increasing the number of children in separated families receiving maintenance; and (equally relevant from a child poverty perspective) the level and regularity of sums paid. At present, child maintenance receipt figures from the Government's national survey are a year and a half out of date by the time they are published. Given the priority given to child poverty reduction in the child support reforms, it is vital that policy makers know far earlier whether the measures taken are working.

Ensuring that more children benefit: the child maintenance disregard

  9.  It is hard to reconcile the White Paper's statement that "tackling child poverty is the first and most critical test for reform" with the proposed timetable for extending the child maintenance disregard. The 2008 extension of the current £10 disregard to `old scheme' child support cases will be a welcome, if belated, `catch up' measure—finally implementing a reform first announced in 1998 but delayed due to implementation difficulties. However, as the White Paper itself acknowledges: "reclaiming most of the money for the State, rather than passing it through to the children, still means that neither parent has a strong enough incentive to cooperate. This undermines the extent to which child maintenance can contribute to the eradication of poverty."[9] It is therefore very disappointing that proposals to significantly increase the child maintenance disregard will not take place until 2010-11.

  10.  There is a danger that, by removing the requirement to apply for child support for parents with care on benefit in 2008, but not significantly increasing the financial incentives to parents to make maintenance arrangements until 2010-11, there will be a period of up to two years when the incentives to seek and pay maintenance for children in the poorest households will be small—contributing to the risk that the Government's 2010 target of halving child poverty will be missed. One Parent Families therefore calls for the date of implementation of the higher disregard to be brought forward.

  11.  A major reason for the delay in implementing a higher maintenance disregard appears to be Treasury fears that such a move might undermine lone parents' incentives to go into work. One Parent Families argues that these fears are misplaced, because:

    —  The potential of access to full maintenance whilst still on benefit gives a lone parent a greater incentive to seek it at that stage, so that it is established before she starts a job. Research suggests that what lone parents value is certainty of income; and it is the lack of certainty which can make the transition to work daunting. At present, some lone parents on benefit are not even aware how much child maintenance is being paid. This makes it difficult to plan for a return to work, or to realise the extent to which the maintenance could act as a `financial cushion' when starting work, when there can be a hiatus in switching to tax credits and adjusted housing benefit, plus the shock of new expenses.

    —  The theoretical model, which proposes a reduced work incentive as a result of a narrowing gap between out-of-work and in-work income, takes no account of behavioural factors, which are reinforced by the `active' benefits regime operated by Jobcentre Plus. For most lone parents, the decision to seek work is a more complex matter than the scale of the initial financial reward. It can involve questions of personal identity, and longer-term goals: being seen as `more than a mum'; earning pride and self-respect as a provider; and being a role model to children. Work can also offer important social networks and a relief from social isolation. We know that most lone parents want to work; regular child maintenance is an important part of the jigsaw in making it possible.

    —  US research cited by Sir David Henshaw indicated that, where trialled, a full maintenance disregard had no negative impact on employment levels among lone parents. Child support payments increased and there was greater cooperation with the formal system.[10]

  12.  One Parent Families continues to believe that child maintenance payments should be disregarded completely within Income Support, JSA, Housing and Council Tax Benefits, both to maximise the potential financial benefits to children in poor families and on the pragmatic basis of administrative simplicity. To retain a maintenance disregard, even at a significantly higher level, requires a level of interactive working between C-MEC and Jobcentre Plus—to monitor payments, adjust benefits and check for fraud—which has so far proved very difficult and costly to do in practice. A third of parents with care on benefit have a partner also on benefit,[11] and we know that 60% of lone parents on benefit on the new scheme have a child support calculation of £10 per week or less.[12] Therefore, the scale of the operation to check whether a higher maintenance disregard should be applied would be out of all proportion to the numbers likely to be affected.

Encouraging and empowering parents to make their own arrangements and how best to encourage access to support services

Parents must have a free choice to use C-MEC or not

  13.  OPF agrees that all parents should have the opportunity to make private arrangements between them for child maintenance, without compulsory State intervention. Where they occur, such arrangements have been shown to work well, essentially because both parents have agreed them. Recent findings by the National Centre for Social Research found that couples were more likely to have agreed `maintenance direct' arrangements (where the non-resident parent pays maintenance direct to the parent with care, unsupervised by the Agency) where the break-up had been more amicable, where there was an ongoing relationship after the break-up, and where parent shared major parenting decisions.[13]

  14.  However, the sad truth is that a great many ex-partners are unable to agree their own arrangements for child maintenance at all; or, having made an arrangement, it proves unsatisfactory or is not kept. The 2004 Families and Children Study showed that 51% of lone parent families had no child maintenance order or agreement, and that even when there was an order or agreement, in a third of cases it was not being paid. Of the lone parents who did get paid, 37% said they didn't always get it all, or it did not always arrive on time.[14]

  15.  Research indicates that maintenance is less likely to be paid where relations between the parents are poor or non-existent; or where the non-resident parent has a fluctuating or modest income.[15] Analysis of non-resident parents currently using the Child Support Agency indicate that half of them have no contact with the parent with care. One in five CSA cases report they have never lived with their CSA partner and 38% of parents with care report they have a tense relationship with their CSA partner.[16] At any one time a quarter of non-resident parents using CSA are on benefit[17] and 7% are self-employed.

  16.  It remains to be seen how many parents with care, who currently are required to use the Child Support Agency because on benefit, will use C-MEC when given the choice. The indications are that a substantial proportion will still choose to do so. When parents with care using the Child Support Agency were asked in 2001 if they would continue to do so if given the choice, 48% of them said they would stick with the Agency (compared to 20% of non-resident parents).[18] We would warn against too optimistic a view of the reductions in caseload as a result of parents with care deciding they do not need C-MEC's services in future.

  17.  The National Centre for Social Research, in an extensive quantitative survey, found that, of parents who had chosen to use the Child Support Agency (ie. not those on benefit) 96% of parents with care and 89% of non-resident parents who were using the Child Support Agency were reluctant to switch to private payments (via `maintenance direct) between themselves and the other parent. The most commonly cited factors among parents with care included:

    —  An uncertainty about being paid (68% of all PWCs using the Agency);

    —  A bad relationship or lack of trust concerning the ex-partner (61%);

    —  A lack of certainty about being paid the right amount of money (52%);

    —  A lack of certainty about being paid on time (52%);

    —  A wish not to have contact with ex-partner (35%);

    —  The fact that the CSA would not chase up payments (33%); and

    —  The lack of proof of non-payment (33%).[19]

  18.  The White Paper fails to acknowledge that what may seem advantageous to the non-resident parent about private arrangements: that they are flexible as to the level and timing of payments, and do not involve supervision from C-MEC, may be seen as potential disadvantages to the parent with care looking after the children: payments are not regular, are for lower amounts than the child support formula, and if not paid, do not result in immediate intervention by C-MEC. In this situation, the interests of the parent bringing up the children must have priority.

  19.  There is a suspicion that the principle of "encouraging and empowering parents to make their own arrangements wherever possible" may be based, not on what is in the best interests of parents looking after children, but because it makes business sense for the new government child support service. According to the Government's response to Sir David Henshaw's report, "the current system involves wholly disproportionate effort to move small amounts of money between relatively poor families".[20] Potentially there is a tension between a "pared down" agency where parents are "encouraged" to make their own arrangements (essentially because the system becomes too expensive and can't cope if too many people use it); and what might be in best interests of parents with care and their children, where they might be better off both financially and emotionally in having C-MEC act as an intermediary and firm hand, particularly right at the start.

  20.  It would be good to give all parents access to sound advice on their child maintenance options, and support if they encounter difficulties. But the message must be advertised very clearly that either parent has a right to make a claim to C-MEC for child support at any point, and that C-MEC will intervene swiftly if voluntary payments are not made. Otherwise, it opens the way to non-resident parents getting away with "messing around"—making late, irregular and partial payments, knowing that C-MEC will prevaricate before intervening and will not collect arrears. Lone parents and their children will be the losers.

What information and guidance to parents need?

  21.  In relation to the provision of information and guidance on child maintenance, we would argue that the White Paper is proposing too narrow a view in focusing simply on assistance needed to make private arrangements. Parents need a fully independent discussion concerning the different options for seeking child maintenance, and the pros and cons of each. As discussed above, private arrangements are not always best and parents should not be pushed down this route if they consider it unsuitable. Moreover, the need for information and guidance is not simply about whether to make a voluntary arrangement or use C-MEC. Other questions can arise concerning child maintenance, for example, whether the non-resident parent has divulged his true income; what to do if maintenance is reduced, becomes erratic or ceases; what to do if the non-resident parent disappears or moves abroad. Parents' need for advice about child maintenance is not just at the point of separation. Child maintenance is a long-term commitment, and new obligations, new personal commitments as well as changed financial circumstances can all affect the arrangements. Research on the advice needs of lone parents commissioned by One Parent Families (see above), found that problems with child support/child maintenance were long-lasting, extending well beyond the initial separation.

  22.  Moreover, for couples who are separating, the question of child maintenance cannot be considered in isolation; there is a need for discussion of other related matters such as rights on divorce or after a period of cohabitation, housing, debts, contact, childcare and future employment. A voluntary agreement concerning child maintenance is more likely to stick if both parties have understood and dealt with the range of issues which need to be sorted out at that point. Two recent reports from the Department for Constitutional Affairs have highlighted how difficult it can be for individuals experiencing relationship breakdown to access the full range of legal and advice services they need.[21]

Does the infrastructure exist to provide the services parents need?

  23.  The White Paper asks how best to encourage access to support services for parents to help them to agree a child maintenance arrangement, indicating that "there will be a major role for the third sector" here.[22] But there is a preliminary issue which the Government must address: the difficulties the third sector would have in providing such services, unless additional resources are found to provide the necessary advice and guidance infrastructure.

  24.  At present, there is a significant shortage of informed advice and support for parents on child maintenance issues. Research commissioned by One Parent Families in 2004 found that one-third of lone parents with child support through the CSA could not find the advice help they needed.[23] The conclusion reached was that there was a need for further and, arguably independent advice, which did not appear to be being met to a great degree either by solicitors or Citizens Advice Bureaux.

  25.  This initiative comes at a time when existing services relevant to separating and separated couples are under threat due to new restrictions on legal aid funding. Citizens Advice—one of the main providers of specialist social welfare advice—has warned that, as a result of the proposed new contracts, it is likely that a number of CABx will cease to offer legal aid and that the services bureaux can provide will be reduced.[24] The Law Society has expressed similar concerns in relation to solicitors' firms offering legal aid. One Parent Families is very worried at the impact a diminution of such specialist services would have on lone parents' access to the advice services they need, and which are already in short supply.

  26.  A proper child maintenance service needs a national infrastructure of services which can offer both one-off advice, but also informed and tailored information delivered face-to-face if desired, plus guidance and support, assistance and legal help as necessary to both parents. Each parent must have access to a service they feel they can trust to understand their needs. Inevitably, when resolving financial matters on separation, including the arrangement of child maintenance, there can differing perspectives. Any service must recognise each parent's right to have access to their own separate adviser, so that no conflict of interest arises.

  27.  The Secretary of State has made clear that he expects the cost of information and guidance services to parents on child maintenance to be borne from within the DWP's own budget.[25] We already know that the Department is subject to tight spending limits during the period of the next Comprehensive Spending Review (with reductions of 5% per year between 2008-09 and 2010-11). In reality, this will constrain what can be achieved.

  28.  One Parent Families would recommend that, in order to make best use of new DWP funding, at a time when budgets across the legal and advice service field are under pressure, there should be a wider integrated cross-Government strategy to assist parents to deal with the range of issues which can accompany family breakdown. This could include possible mediation in negotiating workable post-separation arrangements; information and advice (both by telephone and face-to-face) on the range of practical issues which can arise, including child maintenance; and legal interventions, particularly around divorce and cohabitation rights. This calls for a wider spending settlement involving a range of central Government Departments and local authorities working together.

A register of private maintenance agreements

  29.  OPF has limited faith in a register of private agreements as a means of increasing the flow of maintenance payments to children. Private agreements between parents can differ enormously in terms of quality and durability. Some agreements, such as those registered with the Courts as consent orders, are carefully wrought agreements arrived at through negotiation, where each parent has had access to legal advice and has a full picture of the other's circumstances. In contrast, some parents come to an arrangement without any access to external advice. There can be an inequality of bargaining power. Recent research looking at financial arrangements between separated couples prior to the involvement of the CSA noted that "overall, non-resident parents appear to wield a disproportionate amount of power over establishing financial arrangements following separation, regardless of the type of arrangement adopted."[26] A parent with care, who comes to feel that a arrangement she had agreed is in fact unfair, should have the freedom to renegotiate that arrangement or turn to C-MEC to arrange child maintenance according to the state system.

  30.  Moreover, private arrangements, by their nature, can be fairly flexible—changing over time in response to the parents' and childrens' circumstances. The register of private agreements would therefore have to cope with applications and re-applications to alter agreements registered.

  31.  We consider it would be a costly diversion for C-MEC to be drawn down the route of attempting to formalize, supervise and monitor what are, in essence, voluntary agreements with no legal enforceability. The best way of ensuring compliance with voluntary agreements is to have an efficient and effective government-run service in the background. That should be the priority.

The role of Jobcentre Plus in relation to child maintenance information/guidance

  32.  OPF is sceptical about the ability of hard-pressed Jobcentre Plus staff to give informed advice and information to lone parents on benefit, which will be trusted, regarding their child maintenance options. At best, we suggest that Jobcentre Plus staff be used to identify parents with care who are not receiving maintenance and to make the case for seeking it, by whatever method—before sign-posting them to other sources of advice and assistance.

  33.  The real problem, from a lone parent perspective, is the culture of non-payment of child maintenance in this country. We would argue that there should be more attention given to the identification and recognition of non-resident parents (mostly fathers) who are living apart from their children, with a view to having a conversation regarding maintenance responsibilities and how they are being fulfilled. This conversation needs to happen particularly at the point when a non-resident parent leaves benefit and goes into work (when any child maintenance responsibilities should start to increase).

  34.  It should also be reiterated that 56.5% of lone parents are now in work and that receipt of child maintenance is very significant for this group in lifting children out of poverty. The White Paper talks of "child maintenance system [ceasing] to operate as an adjunct to the social security system" and instead "[becoming] entirely focused on meeting the needs of children and their parents."[27] Too great a focus on the role of Jobcentre Plus misses a major group in need of advice and encouragement to pursue child maintenance.

A fresh start: the role and functions of C-MEC

  35.  The Child Maintenance and Enforcement Commission (C-MEC) will start work in 2007-08. It will not emerge in its full final form, when all cases will be handled according to a new formula, until 2013. Although the White Paper talks of a `clean break', in reality it would appear that the CSA (its staff and computer system) will simply be re-branded as C-MEC from 2008 onwards.

  36.  How different are the three aims of the new organisation from the existing Child Support Agency? The existing Agency similarly set out to helping parents meet their financial responsibility to their children, and similarly has always aimed to deliver a high quality and efficient service. These are important aims which unfortunately were not realized. The current failure of the child support system has essentially been one, not of aims, but of delivery—including problems with the computer system which still continue, problems of management, and shortcomings with the business model itself. Insufficient attention was given to the fact that a significant proportion of non-resident parents were reluctant to pay child maintenance and therefore attempted to evade their liabilities by a variety of methods. Insufficient resources were devoted by the Agency to the hard business of making them pay.

  37.  The aims of C-MEC differ in seeking to "encourage and empower parents in their role" and "where necessary" require them to meet their obligations. One Parent Families is concerned that policy makers are in danger of making a similar mistake as happened when the CSA was established, in being over-optimistic about the extent to which non-resident parents will cooperate in attempts to persuade them to pay child maintenance—and underestimating the extent to which a culture of non-compliance exists among non-resident parents. It would be grave mistake if a disproportionate amount of money and effort were diverted into encouraging and managing private arrangements, at the expense of running an effective and efficient statutory system focused on delivering adequate levels of child maintenance on a regular basis to children in separated families. The best form of encouragement and empowerment to a parent with care, is to know that there is a purposeful and efficient government machine which backs her right to maintenance for her children.

  38.  A further difference is the proposal that C-MEC will deliver high quality and efficient services through its commissioning role. We have no objection in principal to the use of specialist private sector expertise to deliver services. But a new framework for delivery does not answer the question of what, in practice, will be substantively different and better for customers. The danger is that the contracting out of business becomes driven by a desire to reduce costs and staffing levels, and the complex characteristics of child support customers and their needs are not given the importance they deserve

  39.  One worrying pointer is the contracting out of child support clerical cases to Vertex, a wholly-owned subsidiary of United Utilities, which currently processes around 25,000 cases from an office in Bolton. In an adjournment debate in January 2006, John Bercow MP noted that serious delays were occurring at the Bolton office, with CSA staff having major difficulties in communicating with the private contractors by telephone. The Minister admitted that an operational improvement plan had now been implemented in Bolton to try and improve performance.[28]

  40.  When the Contracting Out (Functions relating to Child Support Order)2006 was debated in July 2006, Lord Hunt explained that, although the Order was partly about filling a "significant capacity gap", it was also about "buying in expertise and learning from the private sector".[29]He hinted that the Department intended to learn from these contracts about "using private sector companies for dedicated tasks".[30]The example of Vertex is not encouraging, and points to the need for lessons to be learned so that customers do not lose out.

The principles guiding the approach to transition

  41.  The principles guiding C-MEC's approach to the transition give only a sketchy idea of what is the most substantial challenge facing the new body: how to transfer old cases (`Scheme 1') and new cases (`Scheme 2' ) to a new `Scheme 3' model, a feat which defeated the previous regime when there were only two models. Questions which arise are:

    —  How will the existing caseload be protected so that child maintenance currently in payment does not cease?

    —  How can the transition be best managed, so that the three schemes do not exist for very long, side-by-side?

    —  What does a `clean break' mean, when there will be `linked cases' spanning different schemes, and similarly, child maintenance arrears to be collected spanning different schemes?

    —  How informed and impartial will the advice and guidance be that is given to existing customers to help them decide whether to make private arrangements for the future, transfer to the new system or opt for the new cash transfer service?

    —  How easy will it be to give parent with care an estimate of the amount of maintenance they can expect to receive under the Scheme 3 model?

    —  How will linked cases be treated?

    —  What decisions are to be made regarding adaptation or replacement of CS2, and has sufficient time been factored in to allow for design and full testing of the new systems, or adaptations needed to existing systems, and any procurement processes necessary?

    —  Given the importance of the present Child Support Agency's Operational Improvement Plan as a foundation for C-MEC, how will C-MEC ensure that preparations for `Scheme 3' do not divert attention from achieving the OIP goals?

  42.  The overriding principle governing the approach to the transition has got to be what is practical and achievable in operational terms. OPF would suggest that the approach has to be based on a strategic assessment of the complexity of the transition process for different cases, with resources subsequently allocated to manage the degree of complexity involved. A balanced approach is needed. It would be a mistake, for example, to allow a `cherry-picking' approach, where the easiest cases are done first—with all the difficult ones neglected. Within this framework, we agree that old cases with a `nil' assessment are a very good place to start, and likely to lead to significant immediate gains for parents with care. It should be noted, however, that, with 55% of old scheme cases having a nil liability (414,298 cases in Decemer 2006), this initial identified priority represents a huge amount of work, and will in itself require further segmentation.[31]

The proposed new formula for assessment

  43.  One Parent Families is pleased that the White Paper acknowledges the need to simplify the assessment process for child support, through greater use of information on income held by HMRC. There are obvious advantages to using historic tax-year information to assess child maintenance in terms of simplicity and certainty.

  44.  However, the White Paper is uncommunicative in spelling out the impact the new formula would have on the child maintenance liabilities of non-resident parents, in terms of the proportion of non-resident parents who would end up paying more and the proportion who would end up paying less, compared to their current levels of payment. On one analysis, children in separated families might end up getting less maintenance than now—because the non-resident parent would be making payments on his income up to two years' previously. In the interests of greater transparency, we request that the Government provide more detailed analysis of the likely winners and losers from the new formula, taking into account all the different elements—including the decision to exclude from gross income any tax credits paid to the non-resident parent.

  45.  The use of HMRC data up to two years old raises a number of questions. Most obviously, how much NRPs' incomes are likely to have changed in the interim. One potential problem is the frequency of job change among non-resident parents, and the extent to which they move between spells of employment and unemployment. The White Paper suggests that "historic tax information is close enough to the current financial position of most non-resident parents at the time to be an acceptable and sufficiently robust basis for assessment" (para 4.11). Yet there are likely to be a substantial proportion of non-resident parents—possibly up to a third of employed non-resident parents, and more of self-employed parents—whose income does differ substantially from one year to the next. We warn that this would still pose a substantial administrative burden for C-MEC, along with other changes of circumstance (see below).

  46.  Another question is the extent to which C-MEC would have to go through an annual assessment review exercise at the same point each year, when HMRC tax-year data becomes available. Again, this would pose serious administrative challenges.

  47.   Finally, questions arises about the extent to which a parent with care would be able to predict how much maintenance she would be likely to receive by going to C-MEC , and what information about the basis of any child maintenance assessment would be made available to the parent with care in order that she could make a judgement as to its accuracy.

Self-employed non-resident parents

  48.  Self-employed non-resident parents represent only a fraction of the CSA's current caseload (around 7%).[32] But they cause a disproportionate amount of work—judging by the number of self-employed cases dealt with, for example, on the OPF Advice Line, at Child Support Appeal Tribunals, and reported to the media by disaffected parents with care. This is because of the greater problems in establishing exactly what is the self-employed non-resident parent's income for child support purposes, and the greater scope open to the self-employed to organise their financial affairs to minimise their tax and child support liabilities.

  49.  Assessing all NRPs on gross rather than net income would overcome the issue identified in Smith v Secretary of State for Work and Pensions [2006] UKHL 35, where the NRP's capital allowances for tax purposes had the potential effect of dramatically reducing the income figure used for the assessment of child support. At the same time, there has to be some recognition of necessary capital expenditure in the course of a self-employed NRP's business. Lowering the percentages used in the child support formula is a necessary corollary to relying on gross income—but may not, by itself, be sufficient to reflect business costs. A greater discretion may be needed to allow for departure/variation to reflect legitimate business costs—applied by self-employment specialists with the CSA/C-MEC (see below).

  50.  At present, Agency officials lack the confidence and expertise to properly scrutinise the financial information submitted by self-employed people. One Parent Families would like to see C-MEC developing specialist teams, trained to deal with self-employed cases, to whom all self-employed cases were submitted.

The 25% tolerance level for income changes

  51.  It is proposed that, in future, fixed-term awards will be made, based on tax-year data, and updated each year. Where the non-resident parent states that his current income is lower by 25% or more from historic tax income information, his liability will instead be based on current income. It is clearly a major challenge to devise a method of assessment which is administratively workable, affordable to non-resident parents on an on-going basis, and fair to parents with care and their children. Much depends on the actual level of child maintenance expected, as to whether it is still affordable if the non-resident parent's income is reduced. Without more detailed information from the Government, as stated above, it is difficult to give an opinion on whether the 25% `tolerance level' for adjustment is the right one. One Parent Families has an interest in non-resident parents' liabilities for child maintenance being set at levels which, are both fair to parents with care and widely accepted as affordable to non-resident parents. Not only are they more likely to be paid, but it creates a public climate where non-resident parents who don't pay are regarded as cheating on their children, rather than having a legitimate grievance.

Verification of income

  52.  The use of historic tax-year income will greatly reduce the scope for disputes concerning the non-resident parent's financial situation. Nevertheless, disputes will continue to arise. For example, where the parent with care disputes the non-resident parent's contention that his current income is significantly lower than the historic tax-year figure, or she disputes that the HMRC figure is accurate (for example, because the NRP is working in a family business and there is collusion in presenting a low earnings figure). It must be recognised that income concealment and manipulation by non-resident parents are a real issue, whereby some non-resident parents seek to minimise their liabilities for child maintenance. One Parent Families would like to see the following steps taken:

    —  Full disclosure of information concerning income given to C-MEC by the non-resident parent to the parent with care;

    —  The recruitment of skilled in-house staff with financial expertise to scrutinise and verify financial information given by the non-resident parent, in circumstances where there is a suspicion that the information is not accurate or complete, or a request for the application of the `exceptions regime' has been made;

    —  The merging of staff dealing with the `exceptions regime' and those dealing with the verification of income for assessments, and the creation of close links to staff responsible for criminal enforcement (to enable prosecution of non-resident parents who seek to conceal or give false information about their financial circumstances); and

    —  Provision in the child support regulations to allow a C-MEC official or a Child Support Appeal Tribunal to treat an application for use of the `exceptions regime' as an application to review the child support assessment itself and visa versa (for example, thus allowing the non-resident parent to be required to prove his statements regarding income, rather than the onus of proof falling on the parent with care to prove the grounds for a variation are met).

  53.  The Department for Work and Pensions has discussed with us proposals for closer working with HMRC to identify and investigate non-resident parents who are not declaring income received. This is to be welcomed. But we would be concerned if parents with care, wishing to challenge the non-resident parent's declaration of income, were told that they must take the matter up with the Revenue. There is a danger that HMRC will not necessarily wish to prioritise the investigation of non-resident parents, where the issue is child support avoidance rather than substantial tax abuse. HMRC's priorities tend to be governed by the financial return from any investigation. In child support cases, the focus has got to be on the value of maintenance for the welfare of the children in question. The sums involved may be relatively modest; but in terms of improving the lives of children in poor families, they can make a substantial difference. We consider that the best solution is to have staff carrying out this task within C-MEC—but with very close liaison with investigators within HMRC.

End of year reconsideration

  54.  Non-resident parents will be able to apply in-year for their fixed term child maintenance liability to be reassessed where their income has altered significantly, or where they have ceased employment. This is an important safeguard. However, we suggest that it must be open to C-MEC to review the adjusted fixed award when the full year's tax data becomes available, to ensure that it did fairly reflect the non-resident parent's income over the course of the year. Otherwise, there is a risk of abuse; non-resident parents are more likely to request a re-assessment based on a reduction of income, than report a substantial increase in income.

More anti-avoidance measures needed

  55.  A problem with the child support scheme introduced in 2003 was that it failed to reproduce key anti-avoidance measures present in the previous scheme, namely (i) the power to assume `notional earnings' (for example, where a non-resident parent is being paid wages considerably below the market rate); and (ii) the power to treat a person as possessing income (`notional income') when they have deliberately deprived themselves of income or capital (for example, where the non-resident parent gives up employment in order to evade his child support liabilities).[33] Although various grounds exist for a variation within the new scheme, they are quite tightly drawn and do not cover the range of avoidance tactics which non-resident parents can use. We would therefore urge that these broad based anti-avoidance provisions be re-introduced for the future.

The `exceptions' regime

  56.  In a system of fixed awards, there are likely to be more applications for application of the `exceptions' regime. At present, Child Support Agency officials rarely consider or investigate applications for variations/departures before passing the cases on to a Child Support Appeal Tribunal. Yet appeals to Tribunals can take many months to be heard. For a non-resident parent, determined to avoid payment, an application for a variation can become a form of bureaucratic `sabotage', by which he successfully delays a decision on his liability. We would like to see a system of skilled `first tier' arbitrators within C-MEC, with a power to consider applications for variations, before the matter goes to a Child Support Appeal Tribunal. This would allow in-house critical scrutiny of financial information from the non-resident parent at an earlier stage; reduce the number of cases needing to go to Appeal; and improve the information available to a Tribunal on which to make a decision.

Children in different households and shared care

  57.  It is right that any child support scheme should recognise all children for whom the non-resident parent has a child maintenance liability when calculating his assessment. The system would only be administratively workable and fair, if consistent between all the children involved—using the child support formula, as happens at present.

Shared care

  58.  The White Paper is silent on how the proposed new system should deal with the situation where parents, each with a separate household, are sharing the care of children. Under the present system, the non-resident parent's liability is reduced if the child stays with him on average even one night per week. The present system means that contact and maintenance are inextricably linked, because more contact by the non-resident parent means less child maintenance for the parent with care. Inevitably, the different financial interests of the parents can colour discussions about contact arrangements. The present system also creates administrative complexity, with assessments having to be altered and re-altered, depending on the contact arrangements which take place.

  59.   OPF suggests that, in future, a high threshold should be set for altering assessments where there is shared care. A reasonable amount of shared care—at least two nights per week—should be assumed in the basic assessment.

  60.  OPF does not accept the proposal that where a child lives equally with both parents there should be no child maintenance. Where there is considerable inequality of income, the parent with care may still need financial support to help with her costs both direct and indirect to ensure a reasonably consistent living standard for the child. `Care' is not necessarily equivalent to the provision of financial support.

  61.  Ultimately, it has to be accepted that where parents in two households are sharing the care of children, the costs will be higher. OPF would argue that the State should have a role in supporting parents in this situation, for example, allowing sufficient Housing Benefit for a non-resident parent to allow him to rent large enough premises to accommodate his children.

Tougher enforcement

  62.  One Parent Families very much welcomes the determined thought being given to how to pursue more vigorously non-resident parents who seek to evade paying for their children.

  63.  In addition to new powers however, it is vital that C-MEC devotes the necessary staff, organisational and technical expertise to compliance and debt collection as well as to legal enforcement. One of the biggest failures of the Child Support Agency since it began has been its failure to develop an active and sustained strategy of debt management backed up by sufficient numbers of suitably trained staff. Although there must be clear and automatic referral for legal enforcement in appropriate cases, early intervention when non-payment occurs is the best way of preventing cases escalating to the point that legal action become necessary. Work on this is just beginning within the CSA under its present Operational Improvement Plan, and it is essential that this work is made a priority. One priority must be improvement of IT systems so that non-resident parents with a past history of non-compliance or enforcement action are identified at an early stage and targeted as `high risk' non-payers.

  64.  At the same time, we would warn against painting C-MEC solely as `non-resident parents' worse nightmare'—an organisation to be avoided at all costs. Previous research indicates that non-resident parents dealing with the Agency deeply resented the stigma attached, and that this resentment could in itself feed resistance to paying.[34] There are a variety of circumstances where it is easier for both parents if payment of child maintenance is done through the Agency—for example, where there is a tense relationship and both parties want an intermediary to avoid disharmony; or where the non-resident parent is disorganised and poor at budgeting. Too great a focus on the new Commission as dealing only with hard-core serial non-payers risks creating hostility among non-resident parents contacted by C-MEC, and may deter some parents with care seeking help from C-MEC when they need it. Reflecting the work done by the National Centre for Social Research in this area, OPF suggests a `tailored approach' to non-resident parents by C-MEC, based on their circumstances and past record.[35]

Allow parents with care to instigate enforcement action

  65.  In Secretary of State for Work and Pensions (Respondent) ex parte Kehoe (FC) (Appellant),[36] the House of Lords determined that the Child Support Act 1991 took away a parent with care's private right to enforce payment of child maintenance through the Courts. It determined that that the State had sole responsibility for enforcing child maintenance obligations under the Child Support Act, and had the discretion to decide whether to pursue enforcement or not.

  66.  It is intensely frustrating for parents with care, who see a non-resident parent freely spending sums of capital whilst owing large arrears in child support, that they are completely dependent for enforcement action on an often slow and ineffective bureaucracy. Too often, by the time action has been taken, the funds possessed by the non-resident parent have been spent. Ultimately, it is the parent with care not the bureaucracy administering child support, who has the most direct interest in ensuring that child maintenance, properly determined, is paid.

  67.  OPF would like to see the Child Support Act amended to allow a parent with care to be able to apply to the Family Courts for:

    —  firstly, an investigation of means of the non-resident parent; and

    —  secondly, permission to bring enforcement action for unpaid child support liabilities through the Courts, in circumstances where a sum has been levied against the non-resident parent by the Agency or C-MEC; he has failed to pay some or all of the maintenance due; and the Agency or C-MEC has failed to take effective enforcement action against the non-resident parent in the last three months in circumstances where such action could reasonably have been expected. The Family Courts would be able to grant leave for the parent with care to pursue enforcement action in circumstances where it was thought enforcement action stood a reasonable chance of success. Such a provision would hold the Agency or C-MEC to account for their action or inaction on an individual case, and allow Court intervention to prevent disposal of funds which could be used to pay off child maintenance arrears by the non-resident parent.

Is the shift from predominantly court-based enforcement system to an administrative approach the right way to make enforcement more effective?

  68.  In the longer term, a shift to an administrative approach to enforcement may well be the correct one, allowing speedier interventions with money flowing faster to children. However, the Child Support Agency has had a very poor record in calculating accurately the debts owed by non-resident parent. In 2005, the Child Support Agency Standards Committee found that in 65% of cases where a liability order was sought, the assessment was inaccurate.[37] This is a serious matter, given the range of sanctions which can flow once a liability order has been obtained, and which the White Paper proposes to increase to include an interim `administrative' order withdrawing a passport or driving licence. Unless the basis on which such drastic measures are taken is absolutely rock-solid in terms of accuracy, the system is in danger of becoming oppressive.

  69.   Since 2005, the Child Support Agency has taken steps to try to `quality assure' cases going forward for legal enforcement. One Parent Families would caution against adoption of an administrative approach to enforcement until this quality assurance work has been shown to yield results, so that in the overwhelming proportion of cases going forward for enforcement action, the debt being sought is demonstrably accurate.

Dealing with historic debt

  70.  At present a generation of children are growing up without the child maintenance they are entitled to because the Child Support Agency failed to take debt collection and enforcement seriously in the past. We welcome the assurance in the White Paper that "there can be no question of allowing non-resident parents who are able to pay to escape their responsibilities" (para 5.36).

  71.  The Agency's own figures show that there is at least £1 billion of child support debt which it regards is collectable.[38] Yet under the Operational Improvement Plan, there is a target to collect only £213 million over the three years until March 2009.  This is a pretty unambitious target, but may reflect the poor state of debt collection and enforcement within the Agency at the start of the plan. The recent report by the National Audit Office laid bare how ill-equipped the Child Support Agency has been to perform its debt collection function. Problems identified included:

    —  An inability to obtain a full list of all non-resident parents where a debt has accrued from either CSCS (the original child support computer system) or CS2 (the new computer system);

    —  An inability to mark cases which have a past history of enforcement action, to identify them as `higher risk' cases on compliance;

    —  An inability, within the Agency's accounting systems, to identify the largest debtors or the most persistent offenders; and

    —  The fact that the Agency's enforcement directorate was in fact only dealing with 19,000 of the 247,000 non-compliant and partially compliant cases across the UK—a mere 7.6%.[39]

  72.  Through its Operational Improvement Plan, the Agency is currently taking steps to create an effective debt collection force. We welcome the decision not to seek powers to write off debt that may appear to be unrecoverable, at least until more work is done to understand the large stock of historic debt and the extent to which it can be recovered. Once this work has been done, and new powers of enforcement introduced in 2008, we recommend that the Agency (or C-MEC if it has taken over at that point) re-visit the current debt recovery target for 2009.

  73.  Surprisingly little is said in the White Paper about the `residuary function' of C-MEC in collecting historic debt. But by 2009, if all goes to plan, an effective debt enforcement service should have been created, with a clear strategy in place not only to recover collectable debt, but to resolve cases where the debt is regarded as not collectable, either temporarily or permanently.

  74.  We think this important debt collection work should not be allowed to be overshadowed by the introduction of a new assessment process, and the idea of a `clean break'. Instead, it should be given its own sharp focus. The `historic debt' recovery arm of C-MEC should be set new ambitious targets for debt recovery; have its own budget and staff; and be required to produce an annual report giving full details of its performance against targets, plus comprehensive information about the historic debt, including the number of debtors and individual amounts owed; the strategies used to recover it (including use of private debt collectors) and their success; and what debt is in fact regarded as uncollectable and the reasons why.

  75.  We agree that there is scope to `clear off' debt by seeking negotiated settlements or factoring debts, but are pleased that this will only be done if the parent with care agrees. We recommend that the application of these new methods of dealing with debt should be carefully monitored.

  76.  One concern is that, behind the public decision to write-off only a very small proportion of the total debt, may lie the reality that, in practice, the collection of large sums of money owed to parents with care has been quietly dropped, because in practice they are too difficult or too expensive to collect. We know, for example, that in England and Wales, debts worth £760 million is currently not being pursued by the Agency's enforcement directorate because they is more than six years old and cannot be subject to a liability order in the courts.[40] If, in reality, an internal decision has been made that no action will be taken to recover such money, parents with care need to be told. To quietly allow certain debts to gather dust, without admitting publicly to parents waiting for the money that they will never receive it, is unacceptable.

  77.  Ultimately, the Agency or C-MEC should be open and accountable about its ability or inability to recover money due to parents with care. Where decisions have been taken to longer pursue enforcement action, there should be an obligation on C-MEC to inform the parents with care concerned, and to invite applications for compensation where the parent with care can show that the Agency—through inaction or incompetence—bears some responsibility for the failure to recover the money owed.

Areas not covered by the questions asked in the White Paper

  78.  This submission has covered a number of issues outside the scope of the specific questions posed by the White Paper, in particular, the question of shared care; access to the Courts by parents with care to seek enforcement; and the need for broad anti-avoidance powers (see para 58). But there are two other important topics that we wish to raise. The first is joint registration of births; the second is the question of a maintenance `guarantee.'

Joint registration of births

  79.  One Parent Families opposes the decision to introduce compulsory joint registration of births for unmarried parents on the grounds that it is a disproportionate, and overly punitive approach towards a small—and decreasing—of unmarried mothers who register a child in their sole name. Most unmarried parents do choose to jointly register the birth of a child. In the mid-1960s over 60% of births outside marriage were sole registrations. This figure has been gradually falling and represented only 16.3% of births outside marriage in 2005.[41] The trend has moved steeply in the right direction, and we believe could be accelerated still further by active steps to engage with new fathers and encourage their participation in registration, rather than imposing punitive sanctions on new mothers who are unable or unwilling to name the father.

  80.  The Secretary of State has acknowledged that the proposed new requirement has little, in practice, to do with child maintenance.[42] Mothers who choose to apply to C-MEC for child maintenance will obviously have an identified father in mind. Instead, he sees it as an important part of underlining both parents' responsibilities towards their children. One Parent Families supports the general intention to promote responsible fatherhood but considers that this aim will not be met by passing a law, where failure to comply punishes not the father, but the new mother. We consider this to be too authoritarian an approach, which fails to address the right target. Although safeguards are promised to protect the position of "vulnerable women" and their children, it would still require a new mother who wishes to register her child alone to answer very intimate questions, whether in writing or face-to-face, and be judged (it is not clear by whom) as to whether her reasons are good enough. This is unacceptably intrusive. Moreover, the new requirement could be made unworkable simply by a mother denying she knew the identity of the father.

  81.  We would argue that responsible fatherhood cannot be ordered by the stroke of a pen. Instead it requires positive engagement with fathers at significant points—for example the birth of a baby—to acknowledge their role, and to encourage thinking about their responsibilities. One Parent Families would support more detailed discussions with both parents when a child is born, as to the consequences of putting both names on a birth certificate—both the rights and responsibilities which are crystallised at that point.

The question of a maintenance guarantee

  82.  The option of a child maintenance `guarantee' was rejected by the Henshaw Review on the grounds of cost; removal of the direct link between payment of maintenance and receipt by the family which might reduce compliance; and the creation of possible incentives to families to separate. The Government, in its first response to the Henshaw review, said that "there was little or no support" for a system that would guarantee maintenance in the event of non-compliance by the non-resident parent.[43]

  83.  One Parent Families continues to believe that a child maintenance guarantee does have a crucial role to play in reducing child poverty and making work possible for lone parents.

  84.  The advantage of a maintenance guarantee is that it ensures the regularity of at least a proportion of child maintenance entitlement each week, thus enabling parents with care to make plans for the future based on an assured income. Rather than the consequences of erratic or non-payment of maintenance being borne by the recipient family, the State steps in to protect them in this situation. For lone parents in particular, the financial certainty engendered by receipt of regular maintenance can make returning to work—with all the upheaval that can cause in terms of extra expense and loss of benefits—a far more viable proposition. The living standards of children are also protected.

  85.  The Henshaw Review argued that a maintenance guarantee would be "extremely expensive".[44] Partly, this would partly depend on the level at which it was set. But in any case, we see a maintenance guarantee as being essentially a form of `advance maintenance'—a payment implemented by the State, when the non-resident parent has failed to meet his child maintenance liabilities, and recoverable from him. Thus the cost would be borne by the non-resident parent, and would be recovered by the State. This would hopefully create a much greater incentive on the part of the State to operate a vigorous enforcement and debt recovery strategy. Moreover, there would be nothing to prevent the level of child maintenance collected by means of a guarantee being set at a basic level, lower in many cases that than the actual child support liability due. Effectively the guarantee would ensure that all lone parents with children at least received a `core' amount via the State, upon which they could depend, whilst efforts were underway to recover the full amount owing.

  86.  Henshaw also argued that there would be the loss of a direct link between payment by the non-resident parent and the recipient family which might reduce compliance. It is true that the direct link between payment by the non-resident parent and his children would be lost. However, given that the maintenance guarantee would only apply where the non-resident parent had failed to pay maintenance, we would argue that, in the circumstances, the NRP would have forgone the privilege of that direct payment arrangement. It is hard to see how compliance would be reduced by a guarantee, given that the State would step in to vigorously seek recovery of amounts paid out—thus deterring non-resident parents tempted to default.

  87.  The argument was also made that a maintenance guarantee would give extra support to lone parents and step-families compared to couple families and widows. This is true, but it reflects the essential nature of child maintenance: it is a payment from separated non-resident parents to towards the financial cost of raising their children. Clearly, child maintenance does not apply in other situations.[45] A maintenance guarantee merely allows the parent with care security of access to at least some of the money the non-resident parent should be paying and which the child support system says she is entitled to. It does not remove the obligation on the part of the non-resident parent to meet his child maintenance responsibilities. We reject the proposal that a maintenance guarantee might encourage couples to separate. Such an argument suggests a fundamental lack of belief in the function of child maintenance per se. Child maintenance does not privilege children in separated families above children in couple families; rather it goes some way to addressing the greater risk of poverty to which they are exposed.

  88.   Finally, One Parent Families would question the weight which can be attached to the "new research" cited by the Government as a basis for its statement that "there is little or no support" for a system that would guarantee maintenance in the event of non-compliance by the non-resident parent. The research involved five focus groups involving only 31 parents in total, of whom a mere 17 were parents with care.[46] Over half of these, (10) were receiving maintenance via a `maintenance direct' arrangement. It is not unreasonable to assume that parents who have been able to agree such arrangements do not appreciate the need for a guarantee in circumstances where the non-resident parent does not pay. The authors of the focus group study themselves warn: "As will all qualitative studies, it is not possible to extrapolate from the findings and give a meaningful measure of the number of people holding certain views."

  89.  We accept that, for the time being at least, consideration of a child maintenance guarantee is off the agenda. But, if the present raft of reforms does not significantly increase the proportion of children in lone parent families being supported by both parents, thus reducing child poverty among this group, we shall renew our calls for a maintenance guarantee.

One Parent Families

February 2007

5   A new system of child maintenance, Cm 6979, DWP (2006). Back

6   HBAI data, 2004-05, DWP (2006). Back

7   Families and Children in Britain: Findings from the 2004 Families and Children Study (FACS), DWP Research Report No 340 (2006). Back

8   Child Support and Child Poverty, Professor Jonathan Bradshaw, `Benefits' October 2006. Back

9   Cm 6979, para 2.13, DWP (2006). Back

10   Para 30, Recovering child support: routes to responsibility, Cm 6894 (2006). Back

11   See Table 13.2a, Child Support Quarterly Summary of Statistics, December 2006. Back

12   Cm 6894 op cit. Back

13   DWP Research Report No 404 op cit. Back

14   DWP Research Report No 340 op cit. Back

15   Investigating the compliance of Child Support Agency clients, Atkinson and McKay, DWP Research Report No 285 (2005); An investigation of CSA Maintenance Direct Payments: Qualitative Study, Bell et al, DWP Research Report No 327 (2006). Back

16   Source: National Survey of Child Support Agency clients, Wikeley et al, DWP Research Report No 152 (2001) and CSA administrative data. Back

17   See Table 13.2, Child Support Quarterly Summary of Statistics, Dec 2006. Back

18   DWP Research Report No 152, op cit. Back

19   DWP Research Report No 404, op cit. Back

20   A fresh start: child support redesign, Cm 6895, DWP (2006). Back

21   A trouble shared-legal problems clusters in solicitors' and advice agencies, Moorehead and Robinson, DCA Research Series 8/06 (2006); Separating from Cohabitation: making arrangements for finances and parenting, Tennant et al, DCA Research Series 7/06 (2006). Back

22   para 2.26, Cm 6979 op cit. Back

23   The Advice Needs of Lone Parents, Moorehead, et al, OPF (2004). Back

24   Citizens Advice Briefing for Westminster Hall debate on the future of legal aid, 11 January 2007. Back

25   Hansard, 13-1-2006, col 877. Back

26   An investigation of CSA Maintenance Direct Payments: Qualitative Study, Bell et al, DWP Research Report No 327 (2006). Back

27   Cm 6979, page 47. Back

28   Hansard, 19-01-2006, col 1122. Back

29   Lords Hansard, 20-06-2006, cols 707-720. Back

30   Ibid. Back

31   See Table 15 CSA Quarterly Summary of Statistics, Dec 2006. Back

32   In December 2007 there were 81,700 self-employed non-resident parents on the CSA's books. Back

33   See paras 26 and 27 of the Child Support (Maintenance Assessments and Special Cases) Regulations 1992, S.I. No 1002/1815. Back

34   Investigating the compliance of Child Support Agency clients, Atkinson and McKay, DWP Research Report No 285 (2005). Back

35   DWP Research Report No 404 op cit. Back

36   Secretary of State for Work and Pensions ex parte Kehoe Back

37   Work and Pensions Select Committee minutes of oral evidence, 15-2-2006, HC 920-i Back

38   See Child Support Agency Annual Report and Accounts 2005-06, HC 1402 (2006). Back

39   Child Support Agency-Implementation of the Child Support Reforms, National Audit Office, HC 1174 (2006). Back

40   Ibid Back

41   Office of National Statistics, birth statistics 2005. Back

42   Secretary of State for Work and Pensions in oral evidence to the Work and Pensions Select Committee, 5-2-2007. Back

43   Cm 6895, op cit. Back

44   Cm 6894, Annex II, op cit. Back

45   It should be noted that, unlike other lone parents, widowed parents with children are of course eligible for a non means-tested bereavement payment and widowed parents' allowance based on the deceased's national insurance contributions. Back

46   Future policy options for child support: The views of parents, Atkinson et al, DWP Research Report No 380 (2006). Back

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