Transparency data

Special Category Mechanism roundtable background paper: Written responses summary

Updated 23 February 2026

This is a summary of responses received from the key stakeholders and charities asked to comment on the Special Category Mechanism roundtable background paper published on 1 December 2025. This summary has been created by Cabinet Office officials.

About the responses

36 key representative organisations and charities in the infected blood community were invited to provide a written response to the questions in the background paper (see Annex A for full list). 7 responses were received from: 

• UK Thalassemia Society 
• Families of Deceased Infected Blood Victims UK
• Mono-HCV Haemophiliacs 
• Contaminated Blood Women
• An independent longstanding campaigner
• Haemophilia Wales
• Haemophilia Scotland

All responses were read in their entirety by officials. The written responses were all shared with the TEG for their review. Officials then identified key themes from the written responses to create this summary. The TEG reviewed this document to ensure the themes were accurately summarised.

Summary of themes by question 

Question 1: How do we establish eligibility for SCM in the scheme for those not registered with an IBSS in line with the principles of a tariff based scheme? What evidence is likely to be accessible to people that would meet the other evidential criteria on which the Scheme is based?

Responses pointed to existing forms of documentation as accessible evidence, with some advocating for streamlined processes to avoid further delays:

• The most common evidence suggested includes medical records such as GP and hospital records and treatment histories (e.g with interferon)
• Evidence of disability or inability to work, such as records from the DWP regarding benefit claims, or occupational health records, were also cited
• One response suggested the applicant should contact IBCA with a simple form (similar to the EIBSS SCM form) to make the process easier
• One response suggested to circumvent long NHS waiting times, that a doctor’s referral and/or medical history should be deemed sufficient, rather than requiring sign-off from a specialist or consultant. Another noted that providing new clinical evidence for those not under care of a hepatologist placed “additional burden on the NHS” 
• Two respondents strongly advocated for the principle of self-declaration, noting it has operated successfully for years in Scotland (9 years) and Wales (since 2019)
• One organisation stated that self-declaration promotes a relationship based on trust, recognises the individual’s perception of their health, and avoids “detailed and potentially damaging clinical assessment”
• One respondent suggested that concerns regarding fraud could be managed by “limited verification of a percentage of claims,” rather than universal clinical assessment.

2 responses expressed strong opposition to the 2017 start date, arguing it discriminates against those who died before the mechanism was established. 

Question 2: Can the existing SCM criteria be applied to cases of Hepatitis B infection, which was previously excluded by the support schemes, or do the patterns and causes of long-term disability differ in ways that require different eligibility criteria?

There was consensus in responses that Hepatitis B should be included in SCM-equivalent recognition if the resulting health conditions and long-term disability are comparable to those caused by Hepatitis C.

Multiple responses stated that the existing SCM criteria can be applied, provided the “severity and functional impact of harm are comparable” or the person meets “the same threshold for severe health conditions and long-term disability.”

One response stated that the uncertainty of “reactivation” of Hepatitis B should be taken into consideration and that it was inequitable to limit awards to those with acute HBV to cases where it caused death.

Question 3: How do we determine evidence that links SCM related impacts to impacts on an infected person’s ability to earn or care for themselves?

Responses recommended accessing a wide range of documentation, indicating that no single piece of evidence is sufficient to establish the link. The required evidence fell into four main categories:

• Medical records (GP records, consultant/clinic letters)
• Records of benefits as well as employment and pension records.
• Occupational health assessments
• Social care records
• Contemporaneous evidence i.e personal statements and personal diaries

Multiple responses raised that the impacts on a person’s ability to earn or care for themselves are not generic and require a flexible approach from IBCA. Some quotes are provided below:

• One response said “all applicants will differ” and the question “is not a question we believe can be answered generically.”
• IBCA should “trust the information that was submitted by the applicant and their health care representative.”

One response stated the community needs “detailed information from those who designed the conditions and the framework” of SCM to understand it. This response stated “Seeking a one size fits all approach here is not helpful.”

One respondent highlighted that the legal definitions of medical conditions are “lengthy and technical,” requesting that the IBCA provide “simple terminology” to help applicants understand the nature and effect of these conditions.

Question 4: What observations do participants have on the TEG initial advice that, within the confines of a tariff based scheme, it would only be possible to assess long-term mental health impacts outside of the existing Severe Health Condition in relation to living victims?

One organisation questioned the “appropriateness and essence” of using a tariff-based scheme for this purpose. One organisation highlighted that Wales has had a dedicated psychology service for nearly 15 years, and that Stage 1+ payments were specifically introduced for those experiencing mental health issues or PTSD related to their infection. Two key themes were identified in the responses. 

Distinguishing between the living and deceased for eligibility for SCM, and physical and psychological harm:

• One response argued that restricting the recognition of severe mental health impacts to only living victims reintroduces a distinction between physical and psychological harm that the “Inquiry explicitly rejected.”
• One response stated severe psychological harm is often inseparable from physical harm and contributes to physical decline, loss of employment, and death
• One response stated there is “no principled reason why severe psychological harm suffered during life cannot also be recognised retrospectively.”
• One response disagreed that assessment can only be done for the living, and stated medical professionals that treated the deceased can evidence certain impacts. This response also asked for further discussion of the appropriateness and essence of the proposed tariff-based system.
• One response stated that mental health impacts should be considered alongside severe psychological harm to ensure a clear differential is established between the two types of award.

Some objection to further new assessment

• One response was concerned that forcing a “group of already vulnerable people to have regular mental health checks to qualify is simply unfair”, citing stigma (mentioned in relation to men’s mental health/suicide rates)