Carer Support Payment: equality impact assessment
The equality impact assessment (EQIA) considers potential impacts of the Carer’s Assistance (Carer Support Payment) (Scotland) Regulations 2023 on individuals with one or more protected characteristics.
Annex A
Assessing future changes to eligibility criteria
A key element of assessing options for future changes to eligibility criteria for Carer Support Payment was the Multicriteria Analysis (MCA). The purpose of the MCA was to ensure that a wide range of factors were considered to assess the options for Scottish Carer’s Assistance (now known as Carer Support Payment).
The MCA technique draws largely on qualitative evidence for comparing the options without necessarily focusing entirely on quantifiable or monetisable aspects. The Scottish Carer’s Assistance policy has wide-ranging aims and there are trade-offs in the wider reserved and devolved social security landscape. As a result, it was deemed necessary to use an appraisal technique that would enable a broad range of policy and delivery factors to be considered resulting in distinguishing between the options in a way that would not otherwise be possible. Although there is a degree of subjectivity in this process, using this MCA framework has advantages over informal judgement in that it is based on an explicit evidence base.
Following publication of our Discussion Paper on Scottish Carer’s Assistance aims in March 2021, we worked with stakeholders to develop a final list of 15 options for longer term changes to Scottish Carer’s Assistance eligibility (table 1). We took feedback on the assessment criteria and weighting for the subsequent MCA. Following presentation of the results of this, Scottish Ministers asked that we undertook further analysis of the top nine options. This allowed further exploration of means to address the issues with Carer’s Allowance which had been set out in the Discussion Paper, through changes to eligibility criteria.
The overarching criteria framework of the MCA consists of five core criteria sets.
1. Dignity and Respect
2. Equality and Poverty
3. Efficiency and Alignment
4. Implementation and Risk
5. Economy and Society
Within each criteria set we identified a range of sub-criteria to reflect the policy aims of Scottish Carer’s Assistance. The sub-criteria were also informed by what stakeholders told us would be important for the policy to consider. Equality comprised 35% of the Equality and Poverty core criteria.
Equality Characteristics we sought to consider across the options where possible are[94]:
- Age
- Sex
- Disability
- Ethnicity
- Religion or belief
- Marriage / household type
- Sexual Orientation
Carer’s Allowance encompasses very different caring situations, for example younger carers might forego education opportunities whereas carers leaving work to care are foregoing their salaries. Several of the policies are geared towards different aspects of the benefit be it supporting carers in work or allowing them to combine their caring responsibilities with enrolment in full time education. Understanding if the policy is particularly likely to impact a given group is therefore very important and as a result received the relatively high weight of 35%.
Particularly given that the impact of unpaid caring responsibilities on a much wider set of outcomes, such as employment, earnings, pension contributions, for women is well documented elsewhere we were thus particularly interested in the effect of policies on women[95].
We looked at intersections of the characteristics where the data allowed us, but this was often not possible due to small sample sizes. Poverty and social justice colleagues suggested in the internal experts’ session that the characteristics of priority families as identified in the Tackling Child Poverty Delivery Plan[96] be considered in addition to equality characteristics, these are groups that have been considered in the development of other policies and have reasonable sample sizes within the Family Resources Survey.
This criterion evaluates to what extent each option interacts with and addresses groups of carers who have specific needs[97].
Carer’s Allowance recipients are more likely to be women (almost 73%) and are more likely to be among the older working age group with almost 45% of carers in receipt over 50[98].
For several of the equality characteristics there is some information in the 2020 all clients survey, with around 2,300 of the 3,200 respondents reporting that they were unpaid carers. It provides some indication that the gender reassignment group is likely to be very small, whereas sexual orientation, religion/beliefs other than no belief or Christian, and non-white ethnic minority groups are potentially more numerous on Carer’s Allowance. This is tentative and due to the low response rate, we don’t try to extrapolate proportions from these figures out of concern that respondents are not representative.
Table 1: MCA final list of 15 options
Options ranking |
Equality Impacts |
---|---|
Strongest |
Extend the period for which Carer's Allowance is paid after the cared for person loses their relevant qualifying benefit for any reason (option 3) |
2nd |
Remove the earnings threshold and introduce an hours per week threshold (option 5) |
3rd |
Remove the earnings threshold and introduce an hours per week threshold (option 4) |
4th |
Introduce a taper rate so that the award is reduced gradually as earnings exceed the weekly threshold (option 7) |
Introduce a run-on period after earnings exceed the earnings threshold, with gradual reductions of the award over a period of time (option 8) |
|
5th |
|
6th |
Remove the rule that prevents carers in full-time education from receiving Carer’s Allowance (option 6) |
7th |
Allow carers to add together hours spent caring for up to three people to reach the 35 hours per week caring requirement[99] (option 9) |
8th |
Continue to pay Carer’s Allowance to carers in receipt of State Pension (currently as Carer’s Allowance and State Pension are ‘overlapping benefits’ carers can’t receive both) (option 12) |
9th |
Introduce a Carer Recognition Payment to be paid to carers with ‘underlying entitlement’ to Carer’s Allowance due to the overlapping benefits rule (option 13) |
10th |
Extend the period for which Carer’s Allowance is paid after the death of a cared for person (option 1) Extend the period for which Carer’s Allowance is paid after a cared for person is admitted to hospital or residential care (option 2) |
11th |
|
12th |
Allow more than one person to claim Carer’s Allowance for the same cared for person where they meet all of the other eligibility criteria (option 10) |
13th |
Reduce the caring hours requirement from 35 hours per week to 20 hours per week (option 11) |
Introduce a Carer Recognition Payment for all carers caring for at least 20 hours per week (option 14) |
|
14th |
|
Weakest |
Replace the requirement that a cared for person is in receipt of a qualifying benefit with verification from an approved third party that the carer is providing 35 hours or more of care a week to a cared for person. (option 15) |
Ethnicity, religion and sexual orientation information is available from the Scottish Surveys Core Questions. However, the sample sizes trying to look at those reporting receipt of Carer’s Allowance becomes very small in the population surveys, particularly for smaller subgroups[100]. Consequently, this is only for the broadest group of all unpaid carers and even significant differences here are difficult to interpret as they are likely to be at least in part due to confounding intersectionalities. For example, differences that are due to religion are entangled with those that are due to age. In other cases, small sample sizes mean the estimates are too uncertain to be confident in determining that there are differences such as for sexual orientation.
Other groups we have determined are of interest are care experienced people although there isn’t a great deal of data about this group, and the six family types that were considered as part of work on tackling child poverty. We don’t think that young mothers or households with children under 1 are very numerous on Carer’s Allowance. This is partly because of their age but also because it can be difficult to diagnose very young children. Given that care will be for someone in receipt of one of the disability benefits, and because many carers are disabled themselves, the majority of carers are likely to report living in a household with a disabled person. This means that at least 90% of Carer’s Allowance recipients are likely to fall into a priority group, but leaves large families, minority families and lone parents who are more likely to be in poverty. We believe all of these groups are present on Carer’s Allowance although we have limited information about the first two, with lone parents overrepresented on the benefit. None of the policies under consideration are specifically targeted at these groups but we try to consider the policies more likely to affect them.
Carer’s Allowance is currently more targeted at those with some of the most intensive caring responsibilities than some of the eligibility extensions under consideration. Option 3 scores well because it applies to existing Carer’s Allowance recipients, recognises a particular situation and primarily would reach those caring for children and working age people because these groups are more likely to have their awards disallowed. Although this policy is relatively small, it is one of the few under consideration with the potential to reach lone parents and large families.
Option 5, then 4, followed by 7 and 8 together have scored at the top of equality characteristics. This is because they are a targeted attempt to alleviate a well-documented issue faced by those trying to combine their care with work.
Option 6 is the only policy among those being considered that is more targeted at younger carers, although it could also help carers whose situation is changing. A small proportion of all unpaid carers are currently combining their care with full time education, among the broadest group of working age unpaid carers it is estimated to be around 2%, falling to 1% of those caring for over 20 hours.
Option 9 is a difficult group to obtain more information about as people caring for 35 hours for multiple people, but not any one of them individually. They do not appear in any management information. That said this is a very particular situation. Anecdotally these are people that are balancing care between children and parents with support from others, but we don’t know much more about this group beyond their hours at this time.
Option 12 and then 13 are for carers with an underlying entitlement. The main distinguishing feature of this group is that they are disproportionately older carers in receipt of the State Pension, although the group also includes some working age Carer’s Allowance recipients. They are much more likely to be in receipt of a disability benefit themselves and caring for a disabled partner than for another group and report some of the longest hours cared although it’s not clear how comparable this situation is to working age carers doing similar hours given they are less likely to be foregoing work.
Options 1 and 2 deal with particular situations but are more focussed on recipients likely to be caring for older people.
We expect that Option 10 will largely affect couples caring for children or parents, as such we’d expect most of these payments to be to men. It helps those who already have the additional support of a second carer while excluding those caring alone – groups such as lone parents.
The main distinguishing feature of those benefitting from Option 14 and Option 11 are those caring for 20+ hours as opposed to those caring for more than 35 hours. The 20+ group is significantly more likely than the broader group of unpaid carers to have had their employment affected, but this is still significantly less likely than for Carer’s Allowance recipients. They are more likely to have reduced their hours than Carer’s Allowance recipients however Carer’s Allowance recipients are more likely to have been unable to take up work or left work altogether. There do not appear to be significant differences in age or sex between the groups.
We do not have specific information about Option 15. Whilst there are particular subgroups currently excluded from Carer’s Allowance for which a strong argument could be made, such as those with addictions who we have heard are more likely to have younger carers, the broadening of the definition of disability generally is an extension of the benefit to people with potentially less intensive caring responsibilities. If there is an argument for an extension here it would need to justify why the disability should be recognised for care but not in itself as part of the disability benefits.
Contact
Email: CarerSupportPayment@gov.scot
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