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.
Who was involved in this EQIA, scope, data sources and wider context
Who was involved
Carer Benefits Advisory Group
The Carer Benefits Advisory Group[14] has played a key role in developing the equalities knowledge base for policy proposals, generating ideas, and informing and scrutinising detailed policy development. It is made up of representatives from organisations with an interest in informal caring including national and local carer support organisations, welfare rights providers, and local government. Organisations that have a particular focus on equalities groups are also represented: women (Engender), disabled people (Inclusion Scotland), BAME and gypsy traveller communities (MECOPP), and single parents (One Parent Families Scotland).
In 2017 the group commissioned research on carer equalities issues from the Minority Ethnic Carers and Older People Project. The aim of this was to identify key issues to ensure they were appropriately considered when providing advice to Ministers during the policy development process. Group members also reviewed draft plans for engagement in respect of carers for the Experience Panels. Input from these panels, made up people with experience of social security, inform the development of social security in Scotland. Further detail is provided in the Carer Voice section below. Carer Benefit Advisory Group members participated in the workshops which informed the weighting of criteria, including equalities, for the Multicriteria Analysis for future changes to Carer’s Allowance. The Group held two annual carer benefits equalities event, to scrutinise, share and inform policy, with the first event taking place in December 2021.
In terms of the formal consultation on the replacement to Carer’s Allowance, the Group reviewed plans for targeted workshops with different equalities groups, and accessible and appropriate materials for stakeholder organisations to use with carers. Following the consultation period, a series of workshops to take feedback on policy proposals in light of the consultation responses were held with the Group. During these equalities issues for each proposal were considered.
This EQIA and the related impact assessments were scrutinised at the 2022 Carer Benefits Advisory Group annual equalities event. As well as the organisations referred to above, this event included representatives from LGBT Health and Well-being, Citizens Advice Scotland, Child Poverty Action Group, Marie Curie, Family Fund, Support Mind Scotland, and Social Work Scotland.
Disability and Carer Benefits Expert Advisory Group
The Scottish Government has also undertaken ongoing engagement on proposals for Carer Support Payment through the independent Disability and Carer Benefits Expert Advisory Group (DACBEAG)[15]. The Group’s role was to advise Scottish Ministers on specific policy options for disability and carers benefits due to be delivered in Scotland. The Group, which was independent of the Scottish Government, comprised individuals with significant practical experience of the UK social security system from a range of professional backgrounds. Membership included people working in the disabilities field for organisations such as The Alliance and Inclusion Scotland, in the racial equality field such as the Coalition for Racial Equality and Rights in Scotland, and the Chair of the Scottish Government’s Equality and Budget Advisory Group. The development of Carer Support Payment was considered at six meetings of the Group, and case transfer from Carer’s Allowance was discussed in detail at the Group’s November 2022 quarterly meeting.
Following feedback from DACBEAG on equalities relating to Young Carer Grant, we carried out a review of skills in respect of the equalities impact assessment process within the Carer Benefits Policy Unit, and developed and implemented a staff development plan to address gaps. We also established the Carer Voice Forum to improve knowledge internally on the lived experience of carers, including equalities issues. This is attended by carer policy and carer benefits policy makers, analysts and systems development and operational staff within Scottish Government and Social Security Scotland. Regular presentations and discussions on emerging analysis and issues are held. This has helped us consider in depth the outputs of Scottish Government and Social Security Scotland reports, independent evaluation, and wider analysis and reports on carers circumstances, experiences and views as we have developed policy.
Other organisations
Of the 41 organisations that responded to the consultation, around a quarter were from organisations representing the interests of groups with protected characteristics. The majority of these were disability groups.
As we developed this EQIA, in recognition of our need to better understand impacts on LGBTQIA+ carers, we connected with the organisation LGBT Health and Well-being. This will form part of our longer-term engagement plan to understand the needs of communities where we currently have less knowledge.
A key element in ensuring policy choices for future eligibility changes were informed by our equalities responsibilities was the Multicriteria Analysis. More information on this process is provided at Annex A. Stakeholders, including Age Scotland, Alzheimer’s Scotland, Epilepsy Scotland, Hospice UK, PAMIS and RNIB Scotland, took part in workshops in June 2021 to input on the weighting of the criteria including equalities.
The Carer Voice: Experience Panels
To inform social security policy, the Scottish Government has used Social Security Experience Panels with over 2,400 people across Scotland registered as panel members when the Panels opened in 2017. The Panels involve people with lived experience of the benefits being devolved. ‘About you’ surveys are used to identify the demographic of panel members and ensure a range of voices and experiences are represented[16]. Over half of panel members have caring responsibilities[17]. We have published six reports specifically on carer benefits.
We have also carried out research with relevant stakeholders to specifically target people from seldom heard groups as part of our broader engagement on social security. This includes research into the experience of people who are ‘carers and care experienced’[18].
On Carer Support Payment specifically, we asked Panel members to provide their views on how our new benefit could be different from Carer’s Allowance. The research took place from March to July 2022. A total of 242 Panel members completed a survey with 16 participants taking part in follow-up interviews.
Two surveys regarding the case transfer process were sent out to Experience Panel members in January and February 2019. 404 and 559 responses were received respectively. A series of individual and group interviews were also conducted. Results from both surveys and the interviews were published in 2019[19]. These surveys confirmed that continuing to receive the correct payment at the correct time was most important to panel members.
The Carer Voice: User Research
User Research is being conducted to support the development of Carer Support Payment and the case transfer journey. This is the process of working with carers directly to understand their needs in order to design the systems to learn about, apply for and receive their benefits. This began last year and will continue until the build is completed, with this work being carried on by Social Security Scotland once the new benefit is up and running. This has included work with carers who are disabled or who have long term conditions, carers from black and minority ethnic communities, women who are carers, young carers, older carers and rural carers.
The Carer Voice: Consultation
A number of groups were identified as underrepresented in our evidence base as part of our framing exercise, when reviewing previous carer benefit impact assessments, and through our Carer Voice Forum. Although we do have data, it is not sufficiently specific and/ or robust to inform all aspects of benefit design. These groups are:
- Disabled people who are carers
- Carers from black and minority ethnic communities
- Women who are carers
- Rural carers
- Lesbian, Gay, Bisexual, Transgender and Queer carers
- Faith groups
- Carers with the characteristics of marriage and civil partnership, and pregnancy and maternity
- Student carers
During the consultation period workshops were held with the support of stakeholders to help address gaps in respect of carers with learning disabilities, from black and minority ethnic communities, woman who are carers and rural carers. A total of 151 individuals responded to the formal consultation. However, we do not have a breakdown of these people by protected characteristics
We sought events with other groups but were unsuccessful. We have begun a programme of work to develop stronger links in these areas, and deepen our understanding of the experience and needs of carers groups where we have gaps or have identified particular issues to follow up. This work reaches across the Experience Panel, User Research, carer policy, and the Social Security Scotland equivalent of Experience Panels, Client Panels.
Scope of the EQIA
This EQIA covers the impact that introducing Carer Support Payment will have on recipients or potential recipients who have one or more of the protected characteristics, including the transfer of Carer’s Allowance awards from DWP to Social Security Scotland. It covers policy from launch, and plans for changes to be made further to the completion of case transfer.
Data Sources
For completing this EQIA, data was gathered from a range of sources including:
- DWP Stat Xplore[20]
- Scotland’s Carers 2022[21]
- Scottish Health Survey 2019[22]
- Scottish Health and Care Experience Survey 2017/18[23]
- Scotland’s Census 2011[24]
- Scottish Government Equality Evidence Finder[25]
- EQIA and evaluation of Carer’s Allowance Supplement and Young Carer Grant[26]
- User research for the development of Carer Support Payment
Wider context
This impact assessment is one key part of the suite of impact assessments to accompany Carer Support Payment policy. This EQIA should be read in conjunction with the other impact assessments
- the Business and Regulatory Impact Assessment (BRIA)
- Child Rights and Wellbeing Impact Assessment (CRWIA)
- Data Protection Impact Assessment (DPIA)
- Fairer Scotland Duty Assessment (FSDA)
- Islands Communities Impact Assessment (ICIA)
Contact
Email: CarerSupportPayment@gov.scot
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