Social security system - enhanced administration and compensation recovery: consultation analysis

7 Impact assessments

The Scottish Government uses impact assessments, an evidence-based process during the development of proposals, to consider the possible effects and outcomes on people, businesses, and communities. Impact assessments are also undertaken to ensure proposals align with national objectives and outcomes specified in the Scottish Government National Performance Framework^[15], and mitigate any potential negative impacts. The Scottish Government wants to improve equality through any changes and avoid any negative impacts on any people, groups, communities, or businesses.

Note: few consultation respondents answered Question 39 to Question 42, and not all points relate to the various target groups or specific proposals outlined in the consultation document.

7.1 Equality impact assessment

7.1.1 Question 39: do you have any information you wish to share on the impact of the proposals on groups who share protected characteristics? Please provide details, making reference to the specific proposal or proposals to which your comments relate.

Around one-fifth (21%) of all respondents (third and public sector organisations) provided information on the impact of the proposals on groups, including those who share protected characteristics. Feedback from:

• some third sector organisations highlighted existing inequalities faced by particular groups of people, including women, disabled people, and veterans – it was considered important that the Scottish social security system continues to be informed by people with lived experience to ensure the system was accessible and inclusive
• one public sector organisation suggested that Social Security Scotland should regularly undertake and publish detailed equalities monitoring information, including disability, intersectionality, and information on agency performance, accessibility and decisions, to increase understanding of the impact of proposals on people with protected characteristics

• one public sector organisation reported that eligibility of the Scottish Child Payment was limited by the two-child policy of Universal Credit (a UK Government reserved qualifying benefit for the Scottish Child Payment), as raised in Chapter 3 – they felt that the proposals could create additional flexibility for the Scottish Child Payment to benefit more people, including single parent families
• one third sector organisation felt that the proposal to remove COVID-19 as a valid reason for delays with re-determinations, appeals and applications could have a disproportionate negative impact on disabled people.

7.2 Island communities impact assessment

7.2.1 Question 40: do you have any information you wish to share on the impact of the proposals on island communities? Please provide details, making reference to the specific proposal or proposals to which your comments relate.

Two third sector organisations provided information on the impact of the proposals on island communities. Respondent feedback was general in nature, and not linked to specific proposal(s) outlined by the Scottish Government in the consultation document. Feedback included that:

• the Scottish Government might need to undertake further engagement with island communities to help shape and inform decision-making processes with regards to the social security system in Scotland
• it would be beneficial to consider engaging with intersectional groups, such as women who reside on Scottish islands, to better understand the issues they face
• it would be important that the proposals were island-proofed to ensure the social security system was fair and accessible regardless of where someone lived.

7.3 Fairer Scotland Duty

7.3.1 Question 41: do you have any information you wish to share on the impact of the proposals on reducing inequality caused by socio-economic disadvantage? Please provide details, making reference to the specific proposal or proposals to which your comments relate.

Four organisations from the public and third sector and an individual respondent provided further information on the impact of the proposals on reducing inequality caused by socio-economic disadvantage.

Comments were wide-ranging and not linked to specific proposal(s) outlined by the Scottish Government. Feedback from a few third and public sector organisations was that:

• the proposals to improve client experience and deliver value for money with a principles-based approach might help to tackle existing inequalities faced by particular groups of people, including women and disabled people
• the Scottish Government proposals could possibly go further, and that the system should continue to be informed by people with lived experience of the social security system.

One public sector organisation suggested that the proposals could give greater consideration to the specific needs and circumstances of people who live in deprived areas as well as those who experience digital exclusion.

One individual respondent felt that the proposals could be more forward-looking with regards to combining support available for transport and housing to provide holistic support for children and their families and carers.

7.4 Child rights and wellbeing impact assessment

7.4.1 Question 42: do you have any information you wish to share on the impact of the proposals on children's rights and wellbeing? Please provide details, making reference to the specific proposal or proposals to which your comments relate.

Four organisations in the public and third sector provided further information on the impact of the proposals on children's rights and wellbeing. Feedback from the respondents highlighted:

• the positive impact of the proposals on increasing access to, and take-up of, social security assistance as a way to help tackle child poverty - one third sector organisation noted that the proposals could help advance commitments made in Bright Start, Bright Futures: Tackling Child Poverty Delivery Plan^[16]
• that adopting a principles-based approach with a focus on dignity, fairness and respect was a significant step forward, and that the proposals would have a positive impact on children's rights and wellbeing.

One third sector organisation largely welcomed the proposals but highlighted a need for longer-term planning to deal with unprecedented challenges arising from the cost-of-living crisis.

Similar to Question 39, one public sector organisation reported that eligibility of the Scottish Child Payment was limited by the two-child policy of the UK Government Universal Credit benefit, as raised in Chapter 3.

7.5 Business and regulatory impact assessment

7.5.1 Question 43. do you have any information you wish to share on the impact of the proposals on businesses or organisations in the public, private or third sector? Please provide details, making reference to the specific proposal or proposals to which your comments relate.

Three organisations in the third and public sector provided further information on the impact of the proposals on businesses or organisations in the public, private or third sector. Feedback from these respondents was that the proposals could have a disproportionate impact on the capacity of third sector organisations that delivered welfare rights advice, financial inclusion advice and mental health support.

Two of the responses suggested that the proposals might put additional pressure and strain on such provision which is already dealing with a range of other challenges (such as cost-living-crisis, and staffing shortages). It was suggested that additional resources might be required to increase capacity within the third sector which engages and supports those with lived experience of the Scottish social security system.

The other response suggested that by making improvements and ensuring the social security system is accessible for most people, the pressures on third sector organisations could be reduced and their resources could be used to focus on supporting people in other ways.