Discussion Paper: Energy support for at home medical equipment

• providing a consistent national approach
• linking support to the current cost of energy
• basing support on a fuller assessment of energy need
• delivering support in a timely manner, ideally in advance of energy use

The paper highlights that support for home medical equipment users should be considered separately from support for terminally ill people. While some terminally ill consumers use medical equipment, their additional energy costs often arise from a wider range of needs, including enhanced heating requirements and increased electricity use for hygiene and comfort. In addition, terminal illness support can be delivered through the existing Special Rules for Terminal Illness (SRTI) social security framework, whereas there is currently no equivalent national mechanism for identifying and delivering support to users of home medical equipment. These distinctions mean that policy should avoid conflating the two groups or assuming a common delivery approach.

A range of delivery approaches are considered, including adapting models such as the Warm Home Prescription and trusted third-party arrangements that could assess need and provide energy support linked to actual costs. These approaches could help patients maintain treatment at home, reduce financial hardship, support preventative healthcare objectives and potentially reduce pressure on NHS services by avoiding poorer treatment adherence and preventable hospital interventions.

Ultimately, the paper proposes design principles and delivery considerations to inform the Scottish Government's commitment to explore financial support for households facing electricity costs associated with life-saving medical equipment in the home. The Scottish Government will need to balance improved targeting and health outcomes against considerations of administrative complexity, deliverability and value for money.

This briefing paper considers how future support for energy costs associated with home medical equipment could be designed to better meet the needs of consumers in Scotland in vulnerable circumstances.

Unlike most households, consumers who are dependent on at home medical equipment cannot significantly reduce electricity consumption without jeopardising their health. Their energy demand is often medically determined rather than discretionary. However, the gap in support for energy costs to run at home medical equipment risks patients rationing device usage, or making other difficult decisions around essential household finances, such as “heating vs. eating”. Further, if households cannot afford to run essential medical equipment, the result may be poorer treatment adherence, deterioration in health, increased clinical interventions and avoidable hospital admissions. Energy affordability therefore has direct implications for preventative healthcare and demand management within the NHS in Scotland.

The briefing focuses on the interaction between healthcare delivery and the energy market, and proposes a set of design criteria that could underpin a more effective and consistent approach to energy-related assistance. These include:

• considerations around national consistency
• linking support to the cost of energy
• enabling a fuller assessment of need
• providing support to patients in a timely manner

The briefing aims to support discussions across the Scottish Government, public bodies, the energy sector and health stakeholders on how best to ensure that patients who depend on essential medical equipment are not disadvantaged by the elevated energy costs associated with receiving care at home.

The briefing does not, at this stage, propose specific medical devices that the Scottish Government should provide support for. It does include analysis of the current costs of running some at-home medical devices, however this should be taken as illustrative rather than defining what medical devices are proposed to be covered.

The Scottish Government in their 2026-2031 Programme for Government committed to exploring how they will best deliver financial support for people with electricity costs relating to life-saving equipment in their homes, and further support for the energy costs of those with terminal illness[i]. It is important to draw out the distinction between these different patient groups as the type of support required, and the mechanisms which the Scottish Government can use to provide support, differ.

Earlier this year, Consumer Scotland published an options paper setting out the case, and potential roadmaps, for delivering support to terminally ill patients in Scotland through the existing devolved social security mechanisms[ii]. It is important to recognise that while the unavoidable higher energy costs faced by terminally ill patients may in part be due to the need to use at home medical equipment, there are other drivers of additional costs for these patients. For example, an enhanced heating regime is recommended for vulnerable groups[iii], and these groups may face higher electricity costs through increased use of washing machines and electric showers to maintain good hygiene, provide comfort and reduce the risk of infections, especially if their condition or treatment causes them to be immunocompromised.

Further, it is currently more straightforward to target and deliver additional financial support to terminally ill consumers in Scotland through devolved social security mechanisms. Existing disability benefits in Scotland include eligibility under the “Special Rules for Terminal Illness” (SRTI) route, that includes clinical validation and a fast-tracked route to deliver financial support directly to consumers that meet the definition of terminally ill under social security rules.

In contrast, financial support for energy consumption of at home medical equipment will vary depending on what medical equipment is within scope of any proposed scheme. Medical equipment is also currently prescribed by health authorities in Scotland, without a central data repository detailing both patient details and types of medical equipment prescribed to allow for efficient data-driven targeting of intended recipients at a national level. There is also no equivalent social security marker like the SRTI route that would allow the straightforward delivery of support to eligible consumers.

Therefore, it is important that policy does not conflate these two groups’ needs, or the options and routes to deliver support. Energy support for terminally ill consumers could be delivered using preexisting routes for their particular needs, while proposed support for at home medical equipment will require decisions on what support to provide and through what means, as this paper goes on to discuss.

The benefits of home medical equipment

Across Scotland patients rely on at home medical equipment to manage long term health conditions and receive treatment outside traditional healthcare settings.

The use of at-home medical equipment and greater use of home treatment can save the NHS in Scotland time and resources, as well as save patients and their families travel time and cost, especially for conditions that require regular use such as haemodialysis. At the same time, Scottish health policy increasingly seeks to deliver care closer to home, reducing pressure on hospitals while improving patient experience[iv]. Home dialysis, respiratory support, oxygen therapy and other forms of at-home treatment are necessary to realise this ambition. This approach also aligns with the Scottish Government’s Public Service Reform agenda, especially around objectives to improve preventative approaches and reduce demand on public services by ensuring patients can maintain their treatment at home.

Energy costs and home medical equipment

The success of these health delivery models depends on the clinical provision of essential equipment, and on patients being able to use this equipment safely, affordably and consistently at home.

However, for many households in Scotland the benefits of home medical equipment are accompanied by additional energy costs arising from the use of essential devices such as:

• dialysis machines (such as an Automated Peritoneal Dialysis (APD) machine)
• oxygen concentrators
• ventilators
• continuous positive airway pressure (CPAP) devices
• nebulisers

Patients may use many other types of at home equipment depending on their health condition. To provide an illustration of the estimated running costs of at home medical equipment for patients in Scotland, we have taken the consumption cost of the above machines and calculated their annual running costs based on expected usage and Ofgem’s updated price cap figures for October to December in 2026 for Southern Scotland (Northern Scotland figures would be very marginally higher):

The analysis presented in this paper highlights a number of challenges faced by patients who rely on medical equipment at home, and where current support may not effectively reach them. To ensure that improvements to support mechanisms are effective and capable of meeting patient needs, the design of these changes should be guided by the following principles:

Consideration to be given for a consistent approach across Scotland

Consideration should be given to whether support for home medical equipment could be delivered on a nationally consistent basis, irrespective of where an individual resides. As discussed above, an example of a scheme where health boards can apply their own discretion is under the National Policy for Reimbursement of Home Dialysis Costs. The Policy requires every health board to offer reimbursement, but the schemes are funded from existing board budgets, and they retain discretion over whether to pay above the suggested annual rate, whether to contribute to additional heating costs that dialysis machines need to operate efficiently, and how frequently to pay. Variation between health boards appear to be driven primarily by local administrative capacity and resource constraints, particularly within smaller finance teams, as well as differing local decisions regarding the level of support available for home-based treatment sessions[xxi].

Consideration should be given to where a more consistent approach is beneficial, especially where different levels of support risks exacerbating health inequalities across Scotland, and supporting a preventative approach by reducing the risk of health inequalities linked to a patient’s financial circumstances affecting their health outcomes.

Support that reflects the current cost of energy

The value of support should track the price patients actually pay for their household electricity. Unit rates have risen by 59.3% since the price cap was introduced in 2019, and continue to fluctuate as seen in 2022/23, and again as we enter winter in 2026. A fixed cash amount could quickly lose its real value, a persistent problem for other forms of energy support such as the Warm Home Discount.

There are two broad ways to achieve this:

• Index to the Ofgem price cap – The payment is recalculated at a set point each year, or each quarter, using the cap unit rate for the relevant region. This is administratively simple and requires no information from the patient’s supplier.
• Link to the patient’s actual tariff – Where payments reflect each household’s energy tariff, reflecting the unit rate of any fixed deal they are on. There are international examples of similarly dynamic schemes. In Australia, Victoria’s “Life Support Concession” is directly linked to a household’s own tariff rather than a flat national rate. The concession is calculated as equal to the cost of 1,880kWh of electricity annually, or 470kWh per quarter, paid by the energy supplier onto a bill or balance[xxii]. This is more accurate but requires the supplier to be part of the delivery (see delivery models below).

Either approach produces a “floating” payment where the cash value changes as prices change. This brings three challenges: the payment would need to be reviewed periodically; even yearly movement may complicate Government budget planning; and stakeholders have voiced concerns that variable payments feel less predictable for patients[xxiii]. However, these challenges may be manageable, and an annual change tied to a fixed price cap period would mitigate any erosion in the value of this support.

Support based on a full assessment of medical device costs

Support should reflect the additional energy a patient's equipment requires. This has two components:

• Device consumption – As Table 1 illustrates, consumptions widely by device type, number of devices and hours of use, and can vary significantly between patients using the same device.
• Associated heating - Some equipment only works reliably in a sufficiently warm room. Haemodialysis machines can develop faults with internal temperatures in under-heated rooms. For this equipment, sufficient heating may need to be factored into the cost of running the machine.

There are three ways to establish a patient's energy need, each with different trade-offs between accuracy, cost, privacy, administrative burden and timing of payment:

• Measured Consumption - Smart plugs or current clamps fitted to medical equipment can provide near real-time consumption data[xxiv]. This would provide the most accurate cost of usage, but would require additional funding for the necessary monitoring equipment, adds in additional administrative requirements, and may raise issues around privacy concerns if not sufficiently explained or explicitly consented to by patients;
• Modelled Consumption – A standard estimate for each device type, and where relevant its heating requirement, applied to every patient prescribed that device. This is less accurate, and risks over or underpayment, but carries a low administrative burden and fewer privacy concerns. Accuracy could be improved through a pilot study in which volunteer households, as has been used elsewhere in energy sector innovation programmes, opt in to have equipment and heating consumption monitored, giving a better picture of both the increase in electricity use and the additional heating requirements where relevant.
• Metered Reimbursement – Reimbursing usage recorded by the device itself, as already done in the Oxygen Concentrator scheme. Rather than sharing real-time device usage as suggested in option (a), devices with fitted meters would be read in periodic intervals, and reimbursement would happen after usage in line with these readings. This would be more accurate than modelled consumption, but only possible for devices with such a meter and, because payment folllows usage, it is retrospective, with the risks for lower-income and prepayment customers set out in criterion 4.

Whichever method is chosen, the resulting rates and support value should be clear, transparent and easy for a patient to understand.

Policymakers should consider where financial support can be delivered in advance of usage. Marie Curie found that even where rebate schemes do exist, many patients can face months of hardship before they are paid back in arrears[xxv]. The risk is greatest for patients on prepayment meters, who must pay for electricity before using it, and are therefore at heightened risk of self-disconnection or of rationing their energy usage. This risk is reflected in Consumer Scotland research published in 2023, when the Ofgem price cap was at £2,074 for a typical dual fuel, direct debit household during the last wholesale gas crisis, which found that 73% of disabled people reporting they were rationing energy use due to financial concerns[xxvi]. Viewed through a preventative lens, support in advance avoids the poorer treatment quality, worse health outcomes and potentially avoidable admissions that follow from rationing.

Advance payments are more complex to deliver than retrospective reimbursement. It requires an estimate of future consumption and accurate pricing information, the questions addressed under criteria 2 and 3, and that estimate must rest on robust assumptions if public funds are to be targeted efficiently and offer value for money. Administration may also be more complex and costly than reimbursing confirmed usage, however the delivery models below show that these challenges can be addressed.

Potential delivery models for these criteria

The design criteria for support must be compatible with the delivery model of any future scheme. Below, two established models show how the four criteria can be met together.

Social Prescription (the Warm Home Prescription model) - Energy Systems Catapult have run the Warm Home Prescription model in different parts of the country to tackle poorer health outcomes associated with under heated homes. Under the Warm Home Prescription system, a health professional prescribes a heating "credit" to cover a patient's predicted heating bill. A key worker or energy advice organisation assesses the cost from the patient's household circumstances to assess the value of the credit. An evaluation report found that most homes achieved a healthy temperature as recommended by NICE, with a forward-looking estimate of heating requirements to achieve this desired indoor temperature[xxvii].

Applying this method to medical equipment, a clinician or adviser could estimate device and associated heating consumption, cost it against a patient’s current tariff, and provide a credit in advance. The assessment would also be a natural touchpoint to check whether the patient is on the cheapest available tariff, and eligible for energy efficiency measures that could reduce demand. This model addresses criteria 2, 3 and 4 directly, and if operated under a single national policy, criterion 1.

Trusted Third Party (TTP) - A TTP is an independent body that sits between the patient or health board and the energy supplier. The TTP verifies eligibility and passes the supplier only a validation flag (e.g. this customer is entitled to support) and, in a more developed scheme, the level of support, e.g. based on the number and types of devices. Diagnosis and equipment data are never shared. Because the TTP works through the supplier, a credit can be added to the patient's bill or balance before usage occurs, and the support is guaranteed to be used on energy costs. The model removes the data protection barrier to supplier involvement and is what makes actual-tariff indexation (criterion 2) and advance payment (criterion 4) practical at scale.

There is also a possibility that these two models could be complementary, where a social-prescription assessment could determine the level of support for each patient, and a TTP delivering it as an advance credit through the energy supplier.

Benefits and costs of a scheme

Rising energy costs fall hardest on households managing disability, long-term illness and caring responsibilities. Patients who depend on medical equipment at home cannot reduce that consumption without risking their health. Support for these costs protects financially vulnerable consumers, helps patients maintain their treatment, improves the viability of care at home, reduces avoidable interventions, and helps narrow health inequalities. Any scheme should ensure these benefits are shared fairly between service providers and patients.

However, these benefits must be set against the cost of delivering them. This paper does not estimate the total cost of the scheme. However, a 2022 NHS Scotland estimate put the electricity used by around 139,000 powered medical devices in the community at around £11.5 million a year, excluding oxygen and dialysis machine costs[xxviii]. Applying today’s unit rate would therefore cost around £10 million a year before considering the additional costs of administration of the scheme, associated heating costs, or increased use of washing machines and dryers to maintain hygiene, which would drive costs well above £10 million.

Offsetting NHS savings are plausible but difficult to quantify, and would only be realised in the mid-long term, with the benefits accruing to health boards most directly affected. Consumer Scotland has supported the improvement and delivery of more targeted support for those consumers or patients who need it the most. However, administration of complex schemes, for a relatively low annual payment in the case of some medical devices, could cost as much as the payment. The Scottish Government will therefore need to find a proportionate approach that can deploy support where it may improve health outcomes the most.

This is a consumer matter as much as a health one. And there are innovations in the energy market that provide useful tools for realising this kind of financial support and supporting a preventative approach. Designing a policy with this in mind could make support timely and in line with price changes.

In its Programme for Government, the Scottish Government has committed to exploring how best to deliver this support. The four design criteria in this paper, alongside test for value for money and administrative proportionality, provide an initial framework for it to follow.