Brent Council is to consult on proposals that would cut the current Council Tax Support scheme by £3.3m. The proposals are for three potential options 1) an increase of 19% claimant contribution (the percentage of the full Council Tax that the resident actually pays) for all working age claimants including the vulnerable who are currently exempt; 2) current exempt remain protected but working age non-exempt will pay 51% of the Council Tax; 3) taper off entitlement as income rises so that the number claiming is reduced.
The Council is set to increase Council Tax by 5.99% in the financial year 2019-20. These proposals would take effect in 2020-21 with consultation on the changes taking place between June and September 2019 and going to Full Council in December 2019.
It is worth noting that the report to Monday's Cabinet commits to an equitable scheme but notes under Equality Impact Screening that:
Extract from the Report to Cabinet
£3.3M net saving (£3.96M gross)
i.
Additional
19% claimant contribution for all working age claimants. Current exempt
(“vulnerable”) claimants pay 19%; non-exempt claimants pay 39%;
Or:
ii.
Current
exempt claimants remain protected; additional 31% claimant contribution for all
non-exempt working age; i.e. Non-exempt claimants pay minimum 51% of Council
Tax liability.
Or:
iii.
Introduce
mechanisms to taper off entitlement more steeply as income rises, therefore
making the saving from reduced caseload volumes, rather than the rebates that
the remaining claimants receive.
The above options all represent
extremes which are unlikely to exactly represent the eventual scheme design,
which will be more nuanced, with many aspects – in particular those claimants
treated as “exempt” - under review and likely to be changed. However they
illustrate the difficulty in maintaining the current size of caseload while
attempting to protect the most financially vulnerable. The new scheme is
therefore most likely to incorporate option (iii) to either fully or partially
meet the saving while allowing the scheme still to protect the most financially
vulnerable within it.
Key risks and mitigations
The
Council must be able to show that meaningful consideration has been given to
meeting the saving from alternative measures, e.g. increasing Council Tax,
cutting other services, etc., and why it is proposing to meet the saving by
changing the CTS scheme. If it cannot show this, it leaves itself open to
significant legal challenge.
· Ensure that consultation includes
meaningful consideration of the of alternative funding methods to meet the
saving
· Ensure that Cabinet and Full Council
reports explore the alternative funding methods in sufficient detail and
evidence that that Members have actively considered these
Financial hardship for residents –
· the scheme will be designed to
protect the most vulnerable, but will
necessarily will overall be harsher
than the current scheme
· consideration of a discretionary
hardship fund within the scheme
· consideration of transitional
protection for the most impacted claimants
Council
Tax collection decreases –
- review Council Tax collection processes to enable
greater engagement with CTS claimants before enforcement action commences
Scheme is
not agreed by Full Council by the deadline – - robust project management
IT systems
unable to provide the desired solution (on time) –
- early engagement with IT
providers and strong project management
Scheme is
subject to legal challenge –
· robust scheme modelling
· engagement with stakeholders
· sufficient time taken over drafting
the formal scheme with Legal Services input
Revised scheme
does not deliver sufficient savings and / or further cuts required in following
year
· model alternative schemes including
one providing a larger cut
· design a scheme with further changes
for Year 2 built into it
Equality
impact screening
The proposed scheme has not been
designed yet and there are several options, so it is not possible to be precise
at this stage, however one of the design principles is to build a scheme that
is equitable and proportionate across protected groups (and other claimants),
so specific impacts will be tested in due course and any inequities reviewed
accordingly. That said, there is a potential risk
of a disproportionate impact in certain groups, in particular disabled people,
ethnic groups and (possibly) gender. There is considered to be a much lower
risk in the other protected groups, as no potential scheme designs will feature
these factors explicitly, and the chance of an unintended consequence is
thought to be low – although all aspects will be considered in the EIA.