A pregnant woman with no recourse to public funds gets nothing from Healthy Start, but her British baby qualifies from birth. The department asked the public two years ago whether that gap should close, and has never said what it decided.
Estimated reading time: 6 minutes
In short. In 2024 the Department of Health and Social Care (DHSC) asked the public whether Healthy Start, the scheme that helps buy food and vitamins in pregnancy and early childhood, should be extended to pregnant women with no recourse to public funds (NRPF), alongside a promise to put the existing NRPF children's scheme "on a statutory footing" [4]. Neither has happened. Legislation.gov.uk records no amendment at all to the regulations DHSC said it would change [6], and the consultation's own results page has read that DHSC is "analysing your feedback", unchanged, since the day it was published in 2024 [3]. The guidance for the scheme that does exist [1] was updated again today, with higher rates and a new backdating rule, and states plainly that pregnant women are still not covered [2], with no reference anywhere to the question the department itself raised. Three documented mistakes: four stars.
Healthy Start helps families on a low income buy milk, fruit, vegetables and vitamins, and it has always covered pregnancy: anyone more than 10 weeks pregnant who meets the qualifying-benefit rules can apply, exactly the same as a family with a child under 4 [5]. But the ordinary scheme is "passported" from benefits like Universal Credit, so it is closed by definition to anyone who cannot claim those benefits because of their immigration status. Since May 2021, DHSC has run a separate, non-statutory arrangement to fill part of that gap: British children under 4 whose parent has no recourse to public funds, or no immigration status at all, can get the equivalent payment and vitamins, so long as the family's take-home pay is £408 or less a month [4]. It is a small scheme: DHSC's own figures put it at around 40 families supported in 2023 to 2024, and around 150 in total since it began [4].
A consultation that asked the exact question, then went quiet
In July 2024 DHSC opened a 12-week consultation on this scheme, closing on 23 October 2024. It asked two things at once: whether to place the existing children's scheme into law, and whether to extend eligibility further, to three named groups, one of which was "pregnant women with NRPF or who are subject to immigration controls" [4]. The consultation document did not treat this as an afterthought. It set out specific benefits DHSC wanted views on, including "providing pregnant or breastfeeding women, with NRPF or who are subject to immigration controls, with vitamins like C, D and folic acid to support a healthy diet", and asked directly: "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?" [4]
The consultation's own "Next steps" section committed to two things. First, a specific one: "DHSC intends to amend the Healthy Start Scheme and Welfare Food (Amendment) Regulations 2005 to put on a statutory footing eligibility for Healthy Start for British children who are aged under 4 whose parents are excluded from claiming public funds". Second, a vaguer one, covering pregnant women and the other groups asked about: "DHSC will consider all information submitted as part of this consultation in future policy decisions on whether to extend eligibility further" [4]. No date attaches to either.
The consultation's landing page has not moved since. It tells visitors: "We are analysing your feedback" and "Visit this page again soon to download the outcome to this public feedback" [3]. The page's own metadata, checked directly, records no update since the day it was first published on 31 July 2024, over two years before this piece. "Soon" has no stated meaning and no outer limit.
The statutory promise, checked against the law itself
The clearer of the two commitments is also checkable. DHSC said it intended to amend the Healthy Start Scheme and Welfare Food (Amendment) Regulations 2005, the statutory instrument that governs the mainstream scheme, to bring the existing NRPF children's arrangement into law [4]. Legislation.gov.uk, which tracks every amendment made to every statutory instrument, records this against those regulations: "There are currently no known outstanding effects for The Healthy Start Scheme and Welfare Food (Amendment) Regulations 2005" [6]. More than two years after DHSC said it intended to legislate, no amending instrument has been made, laid or is pending. The children's scheme remains exactly what it was in 2021: an administrative arrangement resting on departmental discretion, not a legal entitlement, for a population defined by having no other recourse at all.
Today's guidance, read against the question DHSC itself raised
The Healthy Start extension guidance was updated again today, 24 September 2026: weekly rates rose to £4.65 for children over one and under 4, and £9.30 for children under one, and a new rule now says that if a family submits all requested documents within 16 weeks of first making contact, payment is backdated to that first contact [2]. Nowhere in that update, or anywhere else in the guidance, does it mention the 2024 consultation, pregnant women, or why the extension continues to exclude them. Its own words are direct: "The eligibility criteria for the extension of the Healthy Start scheme does not include pregnant women" [2].
That silence matters because pregnancy is not a marginal category the ordinary scheme happens to include. It is one of the two headline qualifying groups. The main scheme's own "How to apply" guidance states the rule for everyone else in the country: "You can apply online if: you're more than 10 weeks pregnant or have at least one child under 4 years old" [5]. A woman with no recourse to public funds who is pregnant with a child who will be a British citizen gets nothing from Healthy Start until that child is born; a woman in identical financial hardship who does have recourse to public funds is covered from ten weeks. The consultation that specifically asked whether this should change has been open, unresolved and unexplained for longer than a full pregnancy repeated five times over.
The claims, tested
| The document's own words | What checking the citation shows | Verdict |
|---|---|---|
| "DHSC intends to amend the Healthy Start Scheme and Welfare Food (Amendment) Regulations 2005 to put on a statutory footing" [4] | Legislation.gov.uk records "no known outstanding effects" for those regulations [6]; no amendment has been made in over two years | Stated intention, not delivered |
| "DHSC will consider all information submitted as part of this consultation in future policy decisions" [4] | No date, target or review point is stated; the results page itself has not been updated since publication in July 2024 [3] | A commitment with no working mechanism attached |
| "The eligibility criteria for the extension of the Healthy Start scheme does not include pregnant women" [2] | True, and unexplained; pregnancy is a core qualifying category under the scheme's own mainstream rules for anyone with recourse to public funds [5] | A named exclusion with no stated reason |
The mistakes, counted
The statutory-footing promise has not been kept (1). DHSC told the public in 2024 that it intended to legislate the existing NRPF children's scheme into law. Legislation.gov.uk's own change-tracking shows no amendment has been made to the governing regulations since. Over two years on, the scheme still runs entirely on discretion, for a population with no other legal recourse.
Pregnant women were asked about, then excluded without explanation (2). The 2024 consultation put a direct question to the public, with named benefits attached, on extending support to pregnant women with no recourse to public funds. Today's guidance, updated again this afternoon, excludes them in one sentence and never mentions the consultation, the benefits it identified, or a reason for the gap.
The promised review has no date and has not moved (3). DHSC's own commitment to "consider" further extension "in future policy decisions" carries no timescale. Its results page has told visitors it is "analysing your feedback" without a recorded update since the day it was first published, over two years ago, while the operational guidance for the existing scheme has been rewritten several times in the same period.
Credit where due
The NRPF children's scheme itself is a genuine, if small, act of reach: before May 2021 this group had access to nothing, and DHSC's own figures show it has since supported around 150 families with no recourse to public funds at all, funding real food and vitamins for real children who would otherwise fall through every other safety net [4]. Today's update is a real improvement, not a cosmetic one: weekly rates have risen in line with the main scheme, and a previously undocumented backdating rule has now been set out in writing, giving families a clearer answer than they had yesterday about what happens if evidence takes time to gather [2]. The consultation itself was thorough and specific, asking pointed questions about real trade-offs, including the extra cost and the practical difficulty applicants would have proving eligibility, rather than a token exercise.
Verdict
Four stars, from three documented mistakes. DHSC asked the public, in detail, whether pregnant women with no recourse to public funds should be brought into Healthy Start, and asked in the same breath for views that would let it turn the existing children's scheme into a legal entitlement. More than two years later, neither has happened, the department's own results page has not been touched since the day it was published, and the guidance it issued again today for the scheme that does exist says nothing about either question. A family whose circumstances the department has spent two years discussing is still, today, left reading a sentence that simply says no, with no reason given.
Sources
- Department of Health and Social Care, "Healthy Start extension: application guidance" (publication landing page, updated 24 September 2026, checked 25 September 2026). https://www.gov.uk/government/publications/healthy-start-extension-application-guidance
- Department of Health and Social Care, "Healthy Start extension: application guidance" (guidance, updated 24 September 2026, checked 25 September 2026). https://www.gov.uk/government/publications/healthy-start-extension-application-guidance/healthy-start-extension-application-guidance
- Department of Health and Social Care, "Healthy Start eligibility for families who cannot access public funds" (closed consultation landing page, published 31 July 2024, checked 25 September 2026). https://www.gov.uk/government/consultations/healthy-start-eligibility-for-families-who-cannot-access-public-funds
- Department of Health and Social Care, "Eligibility for Healthy Start for groups who have no recourse to public funds or are subject to immigration controls" (consultation document, published 31 July 2024, checked 25 September 2026). https://www.gov.uk/government/consultations/healthy-start-eligibility-for-families-who-cannot-access-public-funds/eligibility-for-healthy-start-for-groups-who-have-no-recourse-to-public-funds-or-are-subject-to-immigration-controls
- NHS Business Services Authority, "How to apply - Get help to buy food and milk (Healthy Start)" (guidance, checked 25 September 2026). https://www.healthystart.nhs.uk/how-to-apply/
- "The Healthy Start Scheme and Welfare Food (Amendment) Regulations 2005" (SI 2005/3262, legislation.gov.uk, checked 25 September 2026). https://www.legislation.gov.uk/uksi/2005/3262/contents