LGA response to DHSC consultation on Healthy Start eligibility for families who cannot access public funds

The purpose of this consultation was to seek views on whether eligibility for Healthy Start should be extended further to include others who do not have access to public funds. The Department of Health and Social Care (DHSC) was interested in receiving views from those who are subject to, or who work with those who are subject to, the following types of immigration control:

• Those who require leave to enter or remain in the UK but do not have it
• Those who have leave to enter or remain in the UK subject to a condition that they do not have recourse to public funds
• Those who have leave to enter or remain in the UK as a result of a maintenance undertaking

In particular, DHSC welcomed views on whether Healthy Start eligibility should be extended to:

• Non-British children under four from families with NRPF or who are subject to immigration controls
• Pregnant women with NRPF or who are subject to immigration controls

Mothers with NRPF or who are subject to immigration controls with children under one

Current Eligibility for Healthy Start

At present, Healthy Start is restricted to those in receipt of certain qualifying public funds, and those with NRPF, or who are subject to immigration controls, who have at least one British child aged under four.

Do you agree or disagree with the current eligibility criteria for Healthy Start?

• Disagree

Please explain your answer:

The UN Convention on the Rights of the Child outlines societal/government responsibilities towards children as: protection from hazards that may harm, promotion of assets to create wellbeing, provision of services when needs arise alongside a guarantee of personal autonomy in keeping with the age and maturity of the child.

The Convention has 54 articles that cover all aspects of a child’s life and set out the civil, political, economic, social and cultural rights. The convention is universal — these rights apply to every child and the convention entitles every child to claim them. It also explains how adults and governments must work together to make sure all children can enjoy all their rights.

Many immigrant children will grow to become adults in the UK. Improving nutrition in early childhood will have long-term health and economic benefits. It is not equitable to deny any group of children residing in the UK access to mechanisms to improve their nutrition that are afforded to the majority.

Access to adequate nutrition should not depend on immigration status. All pregnant and breastfeeding women, infants, and young children have specific nutritional needs that require a nutrient-dense diet to prevent ill health and support growth and development. Those unable to meet these needs should receive support to prevent poor nutrition and related health issues.

Extending the Healthy Start scheme to children under 4, pregnant women, and mothers with children under 1 who have NRPF would allow families to buy the essential food and drink needed for health and development. The scheme’s stipulations to purchasing milk, fruit, vegetables, pulses, and infant formula reduce the risk of misuse.

Furthermore, the current eligibility for Healthy Start unnecessarily limits access for families that could be eligible for the scheme. The majority of families with NRPF will go on to have access to public funds. Between 2017 and Q1 2023, 64 per cent change of applications were successful, resulting in a little over 20,000 grants of changed status.

Extending Eligibility for Healthy Start

Do you agree or disagree that eligibility for Healthy Start should be extended to non-British children under four from families with NRPF or who are subject to immigration controls?

• Agree

Please explain your answer:

The purpose of the Healthy Start scheme is to ensure that all children have access to vital nutritional support during the critical early years of development. Families with NRPF are at risk of being unable to access the essential vitamins and nutritious foods that their young children need, as many are facing destitution without access to welfare benefits or a nutritional safety net.

It is well established that families facing financial insecurity are more likely to consume energy-dense, nutrient-poor diets, with fewer fruits and vegetables than food secure households. This is especially concerning for young children, who require nutrient-rich diets for healthy growth and development. Nutrients are essential for immunity and brain development, and deficiencies can result in lifelong health issues.

Furthermore, poor quality diets in infancy are associated with excess weight gain by school age, increasing the risk of obesity, type 2 diabetes, heart disease and certain cancers later in life. Children consuming excessive sugar are also at greater risk of tooth decay, which is the leading cause of hospital admissions among children aged five to nine.

No baby or child should be denied access to an adequate diet because of their nationality or their family’s immigration status. Non-British children under four from families with NRPF or who are subject to immigration controls should be entitled to a nutritional safety net, in line with the UK Government’s commitment to ratify the International Covenant on Economic, Social and Cultural Rights, which obligates the Government to secure the right to sufficient food for physical and mental growth for everyone in the UK.

In addition, since August 2024, eligibility for access to Best Start Foods in Scotland has been extended to include non-British children aged under three years with no recourse to public funds. This provides a safety net for the health and wellbeing of pregnant women, infants and children from asylum seeking families who are most at risk of dietary nutritional deficits.

Do you agree or disagree that eligibility for Healthy Start should be extended to pregnant women with NRPF or who are subject to immigration controls?

• Agree

Please explain your answer:

Pregnant women on low incomes with no recourse to public funds (NRPF) are both financially and nutritionally vulnerable. They face a heightened risk of destitution without access to welfare benefits or a nutritional safety net and require a nutrient-dense diet to support the nutritional requirements of the growing baby and an additional 200Kcal/ day in the last trimester of pregnancy.

Financial insecurity can sometimes lead to energy-dense, nutrient-poor diets, with fewer fruits and vegetables consumed compared to food-secure households. This has serious consequences for the health of both pregnant women and their infants. Poor maternal nutrition increases the risk of low birth weight, preterm birth and for their babies, later chronic diseases, such as obesity, diabetes, and cardiovascular conditions, as well as poorer cognitive and emotional development.

Food insecurity during pregnancy is also linked to adverse maternal health outcomes, including antenatal depression, gestational diabetes, excessive or insufficient weight gain, anaemia, and pregnancy-induced hypertension. These health risks are compounded by existing inequalities faced by women with NRPF. Social deprivation is associated with higher rates of overweight and obesity in early pregnancy and higher rates of adverse pregnancy outcomes, including preterm births, low birth weight, and stillbirths.

Addressing these disparities is essential to address health inequalities and improve maternal outcomes for all pregnant women in the UK. Pregnant women with NRPF or subject to immigration controls should be entitled to a nutritional safety net, consistent with the UK Government’s commitment to the International Covenant on Economic, Social and Cultural Right, which requires securing the right to sufficient food for everyone in the UK.

Do you agree or disagree that eligibility for Healthy Start should be extended to mothers with NRPF or who are subject to immigration controls with children under one?

• Agree

Please explain your answer:

Infants under one in families on low incomes and no recourse to public funds (NRPF) are nutritionally vulnerable. Infancy is a critical period of growth and development. During this period, safe, adequate and appropriate milk feeding, and the timely introduction of appropriate complementary foods at around 6 months of age is necessary to support health and optimal growth, including cognitive and immune development.

A 2023 survey revealed that families with NRPF are at risk of food insecurity, facing destitution without access to welfare benefits or a nutritional safety net. This will be making it both harder for some women to breastfeed, and for some families to afford to formula feed.

Women who breastfeed are advised to consume a healthy, balanced diet and an additional 600 kcal per day if exclusively breastfeeding. For many women, food and income security are preconditions to successful breastfeeding. Breastfeeding women with NRPF need to be enabled to access healthy diets, as they cannot afford the sufficient healthy food they feel they need to support their efforts to breastfeed. Infant formula is an essential yet costly food for non-breastfed babies. Rising formula prices have led to unsafe feeding practices in the UK, with serious implications for infant health and development. This is particularly pertinent for families with NRPF, many of whom face destitution and cannot access the resources necessary to safely prepare formula.

Mothers with children under one and NRPF or under immigration controls should be entitled to a nutritional safety net as part of the UK Government’s commitment to the International Covenant on Economic, Social and Cultural Rights, which requires securing the right to sufficient food for physical and mental growth for everyone in the UK.

Extending Eligibility for Healthy Start: Other Groups

Are there any other groups with NRPF or who are subject to immigration controls to whom eligibility for Healthy Start should be extended?

• Yes

Please explain your answer:

The Healthy Start Scheme should be extended to all children and families subject to immigration control whose parents meet the financial eligibility criteria. This would ensure that the scheme achieves its aim of reducing health inequalities by ensuring that women and children “most in need” have access to essential vitamins and nutritious food. Receipt of other support, such as section 17 of the Children Act, should not make families ineligible for Healthy Start. Families with NRPF often rely on this support to meet their basic needs, including food, but the assistance provided through such support schemes is often insufficient to cover the cost of healthy, nutritious food.

Are there any other groups with NRPF or who are subject to immigration controls to whom eligibility for Healthy Start should not be extended?

• No

Please explain your answer:

It is not equitable to deny any group of children residing in the UK access to mechanisms to improve their nutrition that are afforded to the majority.

All children in families who meet the financial eligibility criteria should be able to access the Healthy Start scheme, in keeping with its statutory purpose. Excluding these families will exacerbate health inequalities and undermine the Government’s obligation to protect the rights of all children living in the UK, in line with the International Covenant on Economic, Social and Cultural Rights.

Benefits and Challenges of Extending Healthy Start

Do you agree or disagree that there are benefits to adding these groups to the eligibility criteria for the Healthy Start scheme?

• Agree

Please explain your answer:

Extending the Healthy Start Scheme to children under 4, pregnant women, and mothers with children under 1 who have no recourse to public funds (NRPF) would help the scheme meet its statutory purpose of reducing health inequalities. This would ensure that those 'most in need' due to low income can access the nutritious diet necessary for optimal growth and development, leading to better long-term health outcomes and reduced healthcare costs.

Evidence shows that Healthy Start payments are effective in improving the nutritional composition of household purchases, improving dietary intake (including quantity and range of fruit and vegetables used) and supporting families to establish healthy dietary preferences at an early age McFadden et al, 2014). Improvements have also been shown in the proportion of households meeting their recommended nutrient intakes.

Improving the nutritional status of those ‘most in need’ can help mitigate the long-term impacts of poor nutrition on emotional and cognitive development. Stunted growth due to inadequate nutrition has been linked to impaired cognitive development, lower academic performance, reduced adult wages, and decreased economic productivity.

Currently, there are some individuals with NRPF who are eligible for the Healthy Start  scheme, for example a pregnant woman or parent with a child under four may qualify for the Health Start scheme if they (or their partner) are receiving a list of benefits specified here (i.e. income support, pension credit). By extending eligibility, it would simplify the process for families and for council officers. Furthermore, it could also prevent those that are currently eligible from falling through the gaps and not receiving support due to the current complex exemptions that exist not being understood.

It could also lead to significant savings for councils, who are currently not funded by Central Government for their statutory support for families with NRPF under Children’s Act 1989; the NRPF’s network national data evidences the costs that fall to councils which subsequently cause ongoing challenges. 

There are also longer term economic and social costs to consider; the importance of the first five years in determining a child’s later development and progress in all aspects of life (employment, health, social development, avoidance of crime) has been increasingly recognised. 

Do you agree or disagree that there are challenges to adding these groups to the eligibility criteria for the Healthy Start scheme?

• Agree

Please explain your answer:

It is important that people seeking asylum can access benefits without this impacting on their asylum status. This is possible, as demonstrated by the recent change (August 2024) to the Scottish Government Best Start Foods being extended to non-British children under 3 years.

If you agree, do you have any suggestions for how these challenges could be overcome?

Statutory services for pregnant women and young families, including health visiting, Family Hubs/Sure Start centres, and breastfeeding support, have critical roles to play in ensuring that those eligible are aware of and can access the scheme. Sufficient funding should be invested in local services to support these statutory services, many of which have faced workforce shortages as a result of real term reductions in public health funding. In addition, to prevent delays in the processing of applications and the associated negative impacts on children in these families, the scheme should establish clear guidelines for administrators. and adopt a flexible approach to demonstrating eligibility, which recognises the reality of living with NRPF.

Equality Analysis

What effect, if any, do you think expanding eligibility would have on those who share the protected characteristic of race?

• Positive effect

Please explain your answer:

Current inequity in access to vitamins and healthy food is based on nationality or citizenship. The proposed change to the eligibility criteria would have a positive effect in relation to the protected characteristic of race.

Research shows that families with no recourse to public funds are predominantly families from Black, Asian and ethnic minority backgrounds. 

Extension of the Healthy Start Scheme to families with NRPF would enable families from Black, Asian and ethnic minority backgrounds to purchase the food and drink necessary to support optimal health, growth and development during pregnancy, infancy (for babies and breastfeeding mothers) and early childhood. 

The provision of Healthy Start vitamins would also act as precautionary measure to ensure that nutritional requirements are met at a time when it is difficult to be certain that the diet provides a reliable source of vitamins, especially for families on low incomes.

What effect, if any, do you think expanding eligibility would have on those who share the protected characteristic of pregnancy and maternity?

• Positive effect

Please explain your answer:

Women who are pregnant or breastfeeding are at increased risk of vitamin D deficiency. Extending the eligibility as proposed would have a positive effect in relation to the protected characteristic of pregnancy and maternity through access to Healthy Start vitamins.

The provision of Healthy Start vitamins would also act as precautionary measure to ensure that nutritional requirements are met at a time when it is difficult to be certain that the diet provides a reliable source of vitamins, especially for families on low incomes.

What effect, if any, do you think expanding eligibility would have on those who share any other protected characteristics?

• Positive effect

Equality Analysis: Not extending Healthy Start

What effect, if any, do you think not changing the eligibility criteria would have on those who share the protected characteristic of race?

• Negative effect

Please explain your answer:

Current inequity in access to vitamins and healthy food is based on nationality or citizenship. Not making the proposed changes to the eligibility criteria would maintain the negative effect in relation to the protected characteristic of race.

Families with no recourse to public funds are predominantly families from Black, Asian and ethnic minority backgrounds. Therefore, denying nutritional support to women and children with NRPF, despite meeting the eligibility criteria, will disproportionately affect individuals who share the protected characteristic of race.

Failing to extend the Healthy Start Scheme to families with NRPF would leave them unable to purchase the nutrient dense foods necessary to support optimal health, growth and development during pregnancy, infancy (for babies and breastfeeding mothers) and early childhood. Poor maternal nutrition increases the risk of low birth weight, preterm birth, and chronic diseases in babies, such as obesity, diabetes, and cardiovascular conditions, as well as poorer cognitive and emotional development. Additionally, food insecurity makes breastfeeding or formula feeding more difficult, leading to unsafe or inadequate feeding practices.

What effect, if any, do you think not changing the eligibility criteria would have on those who share the protected characteristic of pregnancy and maternity?

• Negative effect

Please explain your answer:

Pregnant women with no recourse to public funds (NRPF) are highly vulnerable both financially and nutritionally. Many face destitution, lacking access to welfare benefits or a nutritional safety net, and encounter multiple barriers to obtaining food. Yet, they require a nutrient-rich diet to meet the needs of their growing baby, as well as an additional 200 calories per day during the third trimester.

Women who are pregnant or breastfeeding are at increased risk of vitamin D deficiency. Not extending the eligibility as proposed would have a negative effect in relation to the protected characteristic of pregnancy and maternity through limiting access to Healthy Start vitamins.

If the Healthy Start scheme is not extended to pregnant women with NRPF, it will lead to inadequate maternal nutrition, with serious health implications for both the mother and baby. Poor maternal nutrition increases the risk of low birth weight, preterm and for babies, later chronic diseases such as obesity, diabetes, and cardiovascular conditions, as well as poorer cognitive and emotional development.

What effect, if any, do you think not changing the eligibility criteria would have on those who share any other protected characteristics?

• Negative effect

Equality Analysis: Other information

Please provide any further information that you would like DHSC to consider in relation to equality analysis for Healthy Start eligibility for those with NRPF or who are subject to immigration controls.

DHSC should consider how they can remove the variance of value and purchasing power of the Healthy Start scheme to provide consistency for parents by increasing the weekly payments of £4.25 for children aged one to four and £8.50 for pregnant women and babies up to age one in line with inflation and extending payments up until children turn five.

DHSC should ensure Healthy Start materials are promoted in a variety of languages and formats and promoted through various stakeholders, including local councils, health visiting teams and maternity teams.

Arian Nemati
Public Affairs and Campaigns Adviser
Email: [email protected] / Mobile: 07799 038403