Consultation response to the Scottish Government’s Child Poverty Bill for Scotland consultation

Overall statement:

I welcome the Scottish Government’s stated commitment to tackling child poverty and appreciate the attention to the existing evidence base that this consultation shows. The principal reason that any government is concerned to tackle child poverty is because of its negative effects on children’s future outcomes, e.g. cognitive development, psychosocial well-being, educational attainment, physical and mental health, completed schooling, future employment prospects and earning power, to name but a few. It is heartening to see that the impact of living in poverty in childhood itself is also considered in this consultation. The evidence shows that income is the dimension of poverty that has the most significant, adverse impact on children’s outcomes. Therefore, having income as the primary focus of this proposed new Child Poverty Bill for Scotland is very welcome.

However, my concern arises when the Scottish Government itself notes that ‘tackling child poverty is increasingly difficult in the face of UK Government welfare cuts and austerity measures’; ‘we do not hold many of the necessary levers for change under the current constitutional settlement’ and ‘Legislation cannot achieve all of this alone’. While I appreciate that due to these constraints the Scottish Government only has an ‘ambition’ to eradicate child poverty, I feel that setting highly ambitious targets (possibly using the after housing costs measure, within a tight timeframe) while acknowledging that you do not possess the full powers to achieve these targets, and so tempering the wording of the bill with words such as ‘ambition’ and ‘strive to’, has a potential to leave us with a less effective piece of legislation. My fear is that setting highly ambitious targets and only striving to achieve them, will result in a good-looking piece of legislation that cannot achieve its ambition. In other words, it will be all fur coat and no knickers, to coin a common Scottish expression.

I recommend that you should relax the timeframe for the Child Poverty Bill for Scotland, set interim targets, use before and after housing costs measures, include new income measures (see question 5), get rid of some of the so-called measures in the measurement framework and replace them with more rigorous data (see question 10). Most importantly, you should strengthen its language so that the bill has a stronger statement of intent. In conclusion, there is a risk of setting overly ambitious targets that are unachievable but there will be no accountability because there is not a stated strong intention to eradicate child poverty, only an ambition to.


Do you agree with the Scottish Government including in statute an ambition to eradicate child poverty?

I agree with the Scottish Government including in statute a plan, strategy, or programme to eradicate child poverty. I am concerned with the language used in this consultation. The word ‘ambition’ is used throughout as are the words ‘strive to eradicate’. I believe that the words ‘ambition’ and ‘strive’ are vague, indefinite and do not result in any statutory obligation to eradicate child poverty. Using words such as these could mean that the government had succeeded in its ambition to strive to eradicate child poverty even if there was little material change in the incidence and prevalence of child poverty. Logically, the government could not fail to succeed in having an ambition, or in striving, so long as it could demonstrate its efforts. I would like to see a stronger statement of intent.


What are your views on making income targets statutory?

The current child poverty measure of income that the Scottish Government aims to keep, combining both 60% median equivalised income and material deprivation (a multidimensional concept), was reached after a period of extensive consultation using research evidence. Not only has the 60% median equivalised income measure succeeded in capturing the effects of complex economic situations, it is also the official child poverty measure of the EU, OECD and UNICEF, and is now used by other governments. I think it is important to keep this measure and to make income targets statutory. If we were to lose this, we would lose not only a rigorous, well tested and evidence-based measure of child poverty, we would lose the ability to compare ourselves against other nations within the UK, EU and OECD.


How do you think the role of the Ministerial Advisory Group on Child Poverty can be developed to ensure that they play a key role in developing the legislation?

I think the Ministerial Advisory Group on Child Poverty should contain more academic expertise in the field of child poverty. Academics currently working in the field of child poverty would bring an overview of the research evidence and a comparative overview of the situation in other countries.


How can links between the national strategy and local implementation be improved? What could local partners do to contribute to meeting these national goals? This might include reporting and sharing best practice or developing new strategic approaches.

I am mindful of placing any further administrative and reporting burdens on local authorities, particularly if it does not come with ring-fenced funding attached; however, I think this should be a statutory requirement on local authorities to take steps to prevent and reduce child poverty at the local level. Any additional statutory requirement on local authorities should work within the existing legislation of the Community Empowerment Act, the Education (Scotland) Act and the Children and Young People Act to minimise any additional reporting burden.

There is much good work happening at the local level, on a piecemeal basis, with each local body undertaking a range of innovative and successful initiatives to support families living in poverty. My concern is that, due to understandable resource constraints on local authorities, the learning is not being sufficiently shared, or centrally supported, to ensure that all families in Scotland have access to the same level of services to reduce and mitigate, eradicate and prevent child poverty. There are some excellent services around income maximisation, in particular the Healthier Wealthier Children initiative in Glasgow for new parents that I wrote about in relation to child well-being (, that should be rolled out across Scotland with support from the Scottish Government.

There are excellent initiatives being implemented to ‘poverty proof’ the school day, particularly in Glasgow (Cost of the School Day) and Edinburgh (1 in 5 project) – and I’m fortunate enough to work in both of these. A recent film using the Glasgow research by the EIS may be of value to the consultation ( It is my view that poverty proofing in schools should be rolled out across Scotland.

There are other initiatives operating in isolation in different local authorities that should be shared, to benefit children across Scotland. To do this, it would be most practical and cost-effective to have a central group within the Scottish Government, whose responsibility it is to collate and evaluate these initiatives, and to create resources for all of the authorities to enable them to implement the same initiatives. There is much time, effort, and money used (and arguably wasted) by each of the 32 local authorities trying their hardest to develop new initiatives to help local families. This could and should be centrally supported so that: (1) the people of Scotland have the same access to support in the face of child poverty no matter where they live in Scotland; and (2) economies of scale are made.


What are your views on the income-based measures of poverty proposed for Scottish child poverty targets? For example, are there any additional income-based measures you think we should also use (and if so, why)? Are there any alternative approaches to measuring income – for example, as used in other countries – that you think could apply in Scotland?

The government’s focus on income is welcome. While other aspects of income would be a welcome addition, and give a plurality to the measure of income poverty, any new aspects should not replace the current one. The government should continue to measure income as it is currently, that is:

  • absolute low income – measured at 60% of median average income for 1998/99 to measure any increase in the incomes of the poorest families in real terms against a fixed point;
  • relative low income – measured at 60% of contemporary equivalised median income, to measure any increase in the incomes of the poorest families against general rises in incomes in the population as a whole;
  • material deprivation and low income combined – measured at 70% of contemporary equivalised median income and including a measure of lack of material necessities, to compare living standards and material deprivation more broadly; and
  • persistent poverty – measured at less than 60% of median equivalised household income for at least 3 out of the previous 4 years.

These measures provide a quantifiable, comparable threshold against which to measure progress. They also allow for cross-country comparison. Any new measure should be in addition to these current measures.

There is one new measure that would make a welcome addition to these measures. Importantly, there is already a valid and reliable dataset that can deliver the data. This would be a measure of recurrent poverty. Recurrent poverty is when families go into and out of poverty repeatedly over time. The longitudinal dataset following the same families with children over time which is required to derive a measure of recurrent poverty is already available in the Growing up in Scotland (GUS) study. The work that I have undertaken using a measure of recurrent poverty in the GUS data suggests that this measure may be tapping into the idea of insecure or precarious employment. Furthermore, figure 1 below shows that, when recurrent poverty interacts with material deprivation, it is increasingly detrimental to child well-being.

Figure 1 – recurrent poverty, material deprivation and child well-being

md child wellbeing

I would be happy to discuss matters of recurrent poverty and impacts of low quality, insecure employment on families and children living in poverty.


What are your views on the Scottish Government’s proposals for the levels of child poverty that the targets will be set at?

The proposed child poverty targets of relative low income (<10%); absolute low income (<5%); material deprivation and low income combined (<5%); and persistent poverty (<5%) are ambitious, particularly in light of the caveats in the introduction that the Scottish Government does not hold all the levers to enable them to achieve these targets. They therefore need to be looked at in relation to the timescale and whether these measures are to be taken before housing costs or after housing costs. These current end targets seem unachievable on an after housing costs basis and extremely difficult to achieve on a before housing costs basis, unless radical changes to policy and legislation are made by the Scottish Government (specific question(s) answered below). My fear is that setting highly ambitious targets and only striving to achieve them, will result in a good-looking piece of legislation that cannot achieve its ambition. In other words, it will be all fur coat and no knickers, to coin a common Scottish expression. In other countries this has created a political backlash and led to those not in poverty blaming those in poverty for their continuing poverty. Both have weakened support for the maintenance of anti-poverty strategies.

While I welcome and admire how ambitious the Scottish Government is aiming to be in relation to child poverty, I would very much advocate a more pragmatic approach that uses data analysis and modelling to explore the differences between setting the targets on a before or after housing costs basis, and to explore the impact of percentage point decreases in the incidence and prevalence of child poverty over time and what can be achieved before 2030, 2035 et cetera. I would also strongly advocate the use of interim targets.


What are your views on the Scottish Government’s proposal to set targets on an after housing costs basis? For example, are there any disadvantages to this approach that we have not already considered?

I fully support using the after housing costs measure, as it is a more accurate reflection of living in poverty due to necessary housing costs, and I strongly advocate including and reporting on measures of child poverty on an after housing costs basis. However, I question what is to be gained by setting the targets on this measure only. I am concerned that the measure of child poverty would just absorb the cost of housing and that we would cease to be able to highlight the difference in the levels of child poverty before and after housing costs.

The cost of housing is such a pertinent issue, and one that the Scottish Government needs to address to make a real impact on child poverty, that I would not like to see it absorbed altogether but would prefer it to be reported on separately. There are interesting initiatives in other cities across Europe and beyond in relation to housing costs. One is to set rent controls in the private sector, which would help prevent the child poverty caused by the vastly inflated rents of cities like Edinburgh. Another is a restriction on short-term lets (e.g. AirBnB is now banned in several European cities) as these reduce the housing available for residents, increase area rents, decrease community cohesion and increase problems with noise et cetera. These are initiatives that would have a strong impact on the housing problem and are within the powers of the Scottish Government. I really do believe this is an opportunity for the Scottish Government to Be Bold.

Another problem with only using the after housing costs measure is that housing costs are driven by the area in which one lives and the impact of this would be hidden by that one measure alone. At present the child poverty measure is a household measure and not a geographical measure. By predicating the measure on an after housing costs basis it would also become a geographical measure. I think is important to report on both before and after housing costs.


What are your views on the Scottish Government’s proposal to set targets that are expected to be achieved by 2030?

I think 2030 is too soon, it will only be 13 years away when the legislation comes into effect, which is not nearly enough time to achieve the targets. I appreciate that the Scottish Government only has an ambition to strive to achieve the targets, but if it is serious about doing so, it needs to give itself time. It should also set out interim measures so that it can monitor success towards achieving the targets.


What are your views on the proposal that Scottish Ministers will be required by the Bill to produce a Child Poverty Delivery Plan every five years, and to report on this Plan annually?

The current requirement is that the Scottish ministers produce a child poverty strategy every three years and the proposal is to produce a child poverty delivery plan every five years. I think that every five years is too long: if it does not happen at the start of a parliament, it would overlap two parliaments, and possibly two administrations. This would not be good enough and would risk there being no accountability within a Parliamentary term. I think as a maximum it should be every four years.


Do you have any suggestions for how the measurement framework could usefully be improved? For example, are there any influencing factors that are not covered by the measurement framework? Or are there any additional indicators that could be added?

My academic area focuses on child poverty and data analysis. It is highly important that the correct data are collected and used in order to measure progress towards achieving the targets of the Child Poverty Bill. In your measurement framework, there are some measures that are not illuminating and some that are absent but would be illuminating. Using the government’s child poverty strategy framework I would recommend:


You should look at the employment rate of lone parents too as access to education, employment and childcare is a bigger issue for lone parents;

  • you should look at the cost of private nursery care for those under three years old (currently on average £45-50 per day in Edinburgh);
  • you should look at the proportion of (especially new) families claiming, or not claiming, their entitlement to Child Tax Credits, Working Tax Credits, and passported benefits (see Healthier Wealthier Children as before).
  • You should look at the proportion of people who are claiming all benefits they are entitled to. For example, one woman in my study who had received DLA and Carer’s Allowance for her son for over 10 years had never received the disability component of Child Tax Credits as she did not know this existed. There should be an automatic payment of related entitlements when a relevant benefit is received.
  • There should be a measure of how the Scottish welfare fund and other sources of hardship payments are being accessed.
  • You should measure the levels, frequency and spells of benefit sanctions for families with children.


  • I can see you have used the Health Behaviours in School-Aged Children study for some of your measures. While this is a good study and can be broken down by local authority, which makes it valuable, the data are only collected every four years and some of your ‘measures’ have a tenuous relationship with child poverty at best. The indicators that ought to be dropped as they bear little relationship to child poverty are: (1) percent of poorest 15-year-olds smoking (what about vaping? I understand that young people often go straight to vaping bypassing smoking altogether); (2) screen time; (3) finding it easy to talk to your mother; (4) and feeling accepted by pupils in the class. Not only are these data collected far too infrequently to be of any use, they are not measures of child poverty and are very tenuously linked at best.


  • I am very curious about the data that 10% of average incomes is spent on housing. Is this an ambitious target? The average rent of a two bedroomed flat in Edinburgh is £850 per month, a midmarket rent from a housing association two-bedroom flat in Edinburgh is £450 per month, on whose salary is this 10%? Are you including people that have all their housing costs paid for by housing benefit in this measure? I really struggle to understand this figure.
  • There should be a figure that represents how much the Scottish Government is spending on housing, improvements to housing conditions, area deprivation et cetera.

In general, these indicators also need to include figures on what the Scottish Government is doing to make improvements in each of these areas.


Do you have any additional views on a Child Poverty Bill for Scotland?

Yes. Increasingly my and others’ work is showing the importance of poverty on parental (in particular maternal) outcomes and their association with their children’s outcomes. Using GUS data, you can see that maternal mental health is strongly associated with income poverty and especially with material deprivation. I don’t believe it would be possible to mitigate, alleviate or eradicate child poverty by focusing on children only. While this may be difficult from a policy perspective, I fully believe that the well-being of mothers, in particular lone mothers, has to be part of the measurement framework for child poverty. There are many areas in which the Scottish Government can help achieve the ambition to eradicate child poverty by focusing on parents, in particular lone mothers, especially in relation to precarious employment, low levels of education and mental health.

Figure 2 – Maternal Mental Health, longitudinal poverty and material deprivation combined

md mental health

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