please ignore

Just got a response from ESA which shows that the problem is not what I guessed.

You are right, for several reasons:

1. Entitlement to CA and entitlement to a Carer Premium are not separate things that need to be notified individually, there is a Carer Premium because of Carers Allowance.  If they are taking the CA into account as income, they should be taking it into account for the purpose of the premium as well.  The change of circumstance is entitlement to CA, the premium and income are consequences of the change

2. The ground for supersession is not a change of circumstance under Reg 6(2)(a), it is entitlement to a relevant benefit under Reg 6(2)(e).  There is no time limit for this (Reg 7(7)).

3. Even if it was a change of circumstance for the purpose of Reg 6(2)(a), it is not an advantageous change of circumstance because it reduces the amount of ESA(ir) even if the premium is included.  It would therefore take effect from the benefit week in which it occurred under Schedule 3C, and not from the week in which it was notified under Reg 7(2)(b).

All references are the the 1999 D&A Regs SI 1999/991.

Many thanks. Unfortunately - after months of trying to sort this, I’ve got an answer from ESA which suggests that the problem is something else. Apologies.