Disability Assistance for Older People (Scotland) Regulations 2024: Island Communities Impact Assessment

Key findings

54. This section provides an overview of the issues for Scottish island and remote communities that are relevant to these regulations. Island stakeholders have emphasised the importance of understanding the island experience.

55. Each island has its own specific considerations and constraints. Rural Scotland accounts for 98% of the Scottish landmass, with 17% of the population residing there.^[14]

56. At the time of the 2011 Census, Scotland had 93 inhabited islands, with a total population of 103,700. This was 2% of the Scottish population.^[15] Of these islands, only five are connected to the Scottish mainland by bridge or causeway.

57. Part 4 of the Islands Act identifies six local authorities representing island communities. These are: Argyll and Bute Council; Comhairle nan Eilean Siar (Western Isles Council); Highland Council; North Ayrshire Council; Orkney Islands Council and Shetland Islands Council. Amongst them, Orkney, Shetland and the Western Isles are entirely island authorities, while Argyll and Bute, Highland and North Ayrshire cover island regions as well as mainland regions.

Demography and health

58. According to the 2011 Census, 83% of island residents reported their health as being ‘Very good’ or ‘Good’ compared with 82% for Scotland as a whole.^[17] The proportion of island residents with a long-term health problem or disability that limited their day-to-day activities was just under 20%, including 9% who reported their daily activities were limited a lot.^[18] The corresponding proportions for Scotland as a whole were very similar. 21% of island residents were aged 65 and over, whereas the proportion nationally was 17%.^[19]

59. Across the United Kingdom, disabled people have higher poverty rates than the general population. 24% of people over State Pension age with a disability are in poverty compared with 17% of those without a disability.^[20] Data related to disability specific to island communities is not available.

60. In Scotland, 410,000 households in poverty (42%) include a disabled person. 1 in 8 people aged over 65 in Scotland experience poverty in the last year of their life. The impact of social inequalities on health outcomes in older people is well documented.^[21]

61. In August 2022, around 16,500 individuals had an entitlement to Attendance Allowance within the entirety of the six island local authority areas, with around 3,500 of those individuals residing on the islands. This accounted for around 2.4% of those with an entitlement to Attendance Allowance within Scotland.^[22]

62. Although Pension Age Disability Payment is not intended to be an income replacement benefit, it is intended to provide support with helping to meet the extra costs associated with having a disability. The Scottish Government’s approach to delivery is expected to improve outcomes for older people across Scotland, including in island communities, by starting from a position of trust and listening to what individuals tell Social Security Scotland about their personal circumstances while endeavouring to make the right determination at the first opportunity.

Cost of living

63. The cost of many amenities and activities are higher for people living in island communities than those living on the mainland. A lack of choice and accessibility means that shopping, mobile phone services and broadband can be more expensive for people living in island communities compared to those on the mainland. The greater distances and remoteness means that day to day travel, postage, fuel, day-trips and holidays are also more expensive for people in remote communities.

64. Citizens Advice Scotland have identified issues of grid, utilities, digital and travel as key barriers for people in accessible rural, remote rural and remote small towns.^[23] Furthermore, a typical food basket can cost as much as 50% more on island communities in Scotland, while transport can be up to £40 a week more expensive due to longer distances for commuting and a higher price for petrol.^[24]

65. According to Highlands and Islands Enterprise (HIE), household budgets in remote rural Scotland in 2013 were typically 10-40% higher than elsewhere in the United Kingdom.^[25] Although this had reduced slightly in 2016 and has a more modest impact on older people, HIE attributes these extra costs to three principal sources:

• The higher prices that households were required to pay for food, clothes and household goods;
• Considerably higher household fuel bills, influenced by climate and fuel sources;
• The longer distances that people have to routinely travel, particularly to work.

66. The Joseph Rowntree Foundation reported that levels of poverty among disabled people are generally underestimated.^[26] Because disabled people’s needs are often greater than for those without a disability, the cost of living for disabled people is frequently higher. These costs are higher in island and remote communities due to an environment that is less accessible, with higher costs for reasonable adjustments to technology, housing and transport.

67. A range of work is being undertaken by the Scottish Government to address the challenges that people in island and rural communities face. For example, the Islands Strategic Group was established in August 2016.^[27] The group considers strategic issues affecting the island communities of Scotland, and to ensure greater involvement of the relevant councils in helping to identify and design solutions to the unique needs and challenges these communities face.

68. The Scottish Government recognises that both being disabled and living in a remote rural area makes it more expensive to meet material needs and participate in society. While Pension Age Disability Payment is not intended to be an income-replacement benefit, it is intended to provide support with helping to meet the extra costs of care associated with having a disability. For some disabled people, entitlement to Pension Age Disability Payment may bring additional entitlement to other benefits and premiums.

Connectivity and accessibility

69. Alongside the areas identified by Citizens Advice Scotland, research briefings from 2017 for the Islands (Scotland) Bill suggest that residents of islands rely on ferry crossings and air travel to reach the mainland and larger islands to access key services such as secondary and higher education, care, and medical services.^[28]

70. In 2011, the proportion of island households with at least one car or van available was 79%, compared with just over two-thirds (69%) nationally.^[29]

71. In rural remote areas and island communities, disabled people face a lack of access to opportunities that are more readily and frequently available to those on the mainland or in urban areas. Furthermore, a lack of accessibility to employment, education and leisure opportunities can be made more difficult for someone with a physical condition, especially when transport options are limited.

72. Anyone resident in Scotland over the age of 60 is entitled to free bus travel through the National Entitlement Card scheme. Following a public consultation in 2017, the Scottish Government committed to maintaining free bus travel.^[30]

73. This scheme provides free travel on registered local and long-distance bus services throughout Scotland, at any time of day for any number of journeys. The provision of free bus travel allows older people improved access to services, facilities and social networks, therefore promoting social inclusion.

74. The Scottish Government also provides entitlement to a disabled person’s bus pass. At present, Attendance Allowance is a qualifying benefit for a disabled person’s bus pass. The Scottish Government is legislating to ensure that Pension Age Disability Payment provides access to the disabled person’s bus pass as part of the commitment to a safe and secure transfer.

75. Where an individual is entitled to a disabled person’s bus pass, the National Entitlement Card scheme allows for free travel of a companion. A companion can make travel much easier. For example, a companion can help an individual to get on and off buses, carry shopping and communicate with the driver.

76. Bus services in remote and island communities can be unreliable and are often community run. Even where buses are available, they often run rarely and timetables do not always meet the needs of people living in the community. Furthermore, if there is already someone with a wheelchair or pram on the bus it is not always possible for a wheelchair user to board.

77. Not all islands are served by buses and there are not always taxis available. It is known that disabled people on islands rely heavily on neighbours, friends and families driving them as a primary means of transport.

78. The needs of wheelchair users can be different in island and rural communities than the needs of wheelchair users in an urban environment due to more challenging terrain.

79. Transport Scotland has set out the Scottish Government’s intention to reduce inequalities for rural and remote residents as well as disabled people in the National Transport Strategy. ^[31]

80. The strategy has set out policies to minimise the connectivity and cost disadvantages faced by island communities and those in remote rural and rural areas. This includes the safeguarding of lifeline services as well as ensuring transport in Scotland is accessible for all by supporting the implementation and development of Scotland's Accessible Travel Framework.

81. The Accessible Travel Framework sets out a vision that ‘all disabled people can travel with the same freedom, choice, dignity and opportunity as other citizens.' This vision is supported by four outcomes:

• more disabled people make successful door-to-door journeys, more often
• disabled people are more involved in the design, development and improvement of transport policies, services and infrastructure
• everyone involved in delivering transport information, services and infrastructure will help to enable disabled people to travel
• disabled people feel comfortable and safe using public transport – this includes being free from hate crime, bullying and harassment when travelling. ^[32]

82. Research undertaken by the Scottish Government and by stakeholders in 2020 have found that a lack of connectivity in rural or remote communities has been compounded by the impacts of the COVID-19 pandemic.^[33] An absence of good quality internet connection can significantly impact on an individual’s ability to socialise and partake in cultural activities, particularly where people already have difficulty taking part in activities as a result of a disability or health condition.

83. The Scottish Government is working to address some of these connectivity issues through Social Security Scotland’s Local Delivery staff sharing locations with other services so that they are based where people currently go, to ensure that individuals can access advice and support in existing island locations.

84. Social Security Scotland will offer a multi-channel approach, including telephone, paper-based and face-to-face applications to ensure that people are not isolated through a lack of access to technology.

85. Social Security Scotland can also support individuals to gather supporting information where this is needed to support the decision-making process. This includes, if authorised by the individual, gathering supporting information on their behalf if they do not have this to hand. For individuals living in rural or island communities, this may be of particular benefit as it may be difficult for residents to gather supporting information from a professional given the remoteness and lack of connectivity.

Culture

86. Stakeholders have identified potential cultural barriers to applying for Pension Age Disability Payment. This is because of the close-knit nature of island communities. Although there is research that evidences the positive impact of the support provided by close-knit communities, certain barriers may also be present.

87. It is possible that the stigma attached to identifying as disabled could act as a barrier to people applying for Pension Age Disability Payment. The need for privacy and dignity is emphasised by disabled people in remote and island communities.

88. Dignity, fairness and respect underpins how Social Security Scotland will deliver Pension Age Disability Payment, including protecting the privacy of individuals. For instance, Social Security Scotland’s Local Delivery team will share locations with other services so that they are based where individuals currently go to ensure that they can access advice and support in existing island locations. This should help to reduce the stigma of seeking support when applying for Pension Age Disability Payment.

89. Access to information on Pension Age Disability Payment will also be reflective of culture and lived experience. Social Security Scotland will create a range of Pension Age Disability Payment stakeholder resources and content in accessible formats.

90. Such resources will be proactively supplied to relevant stakeholder organisations through the National Engagement Team for organisations to distribute to people in local communities. Social Security Scotland proactively translates information resources into Gaelic, which may be beneficial to some island communities, particularly those residing in the Western Isles, Highlands and Argyll and Bute.

Choice and representation

91. The Scottish Government has heard how there are limited options for people living in island and remote communities with regard to leisure activities, support services and support groups, with the importance of choice being a key theme in previous social security and disability assistance consultations. However, such choices are often diminished or non-existent in rural areas.

92. As previously highlighted, Social Security Scotland’s Local Delivery team will share locations with other services so that they are based where people currently go to ensure that they can access advice and support in existing island locations.

93. Social Security Scotland will also offer a multi-channel approach, including telephone, paper-based and face-to-face applications to ensure that people are not isolated through a lack of access to technology. Further to this, carers, adult children and those with power of attorney will be able to navigate the process of applying for and maintaining Pension Age Disability Payment through Social Security Scotland’s multi-channel approach. People applying for Pension Age Disability Payment will not be required to undergo a face-to-face consultation.

94. The importance of representation has been heard from island communities. The Scottish Government will ensure that individuals can request a third party representative with ease to support them in their engagement with Social Security Scotland. Scottish Ministers believe this strikes the right balance to encourage people in this age group to gain support from friends and relatives when required, while also maintaining their financial independence.

95. Social Security Scotland’s existing appointees process will be extended to Pension Age Disability Payment. This process recognises the vulnerabilities of those who require an appointee, and includes a number of safeguards.^[34]

96. Engagement with key stakeholders, including advice organisations, will be ongoing throughout the development and delivery of Pension Age Disability Payment to ensure that they understand the application process and eligibility criteria to provide representation for individuals.

97. The Scottish Government launched the Social Security Independent Advocacy Service in January 2022. The service is free and supports people who self-identify as a disabled person to access and apply for Social Security Scotland assistance.

98. The service is independent of the Scottish Government and is delivered by VoiceAbility, a charity with 40 years’ experience of delivering independent advocacy services. Advocates from VoiceAbility can support people to have their voices heard, understand and secure their rights under the Scottish social security system, express their wishes and be fully involved in order to make informed decisions.

99. It is expected that the Scottish Government’s approach to delivering Pension Age Disability Payment will help to ensure that individuals can interact with Social Security Scotland in a way that best meets their needs, while having support from friends or relatives as well as independent advice organisations, no matter where they reside in Scotland.

Implementation

100. A communications strategy and comprehensive guidance will be developed in advance of the launch of Pension Age Disability Payment. This will ensure that individuals who are eligible and their families, the third sector, local authorities and advice providers are aware of Pension Age Disability Payment, and have an understanding of the application process and eligibility criteria.

101. The communications strategy will be linked with wider Scottish Government initiatives on improving outcomes for disabled people and for remote and island communities. This will ensure that Pension Age Disability Payment is part of wider efforts to meet the needs of people living in island communities.

102. The Scottish Government recognises that awareness and understanding of Attendance Allowance is often limited, which is especially relevant in rural communities. Scottish Ministers intend to provide clear information about eligibility and the new application process for Pension Age Disability Payment which will be more personalised and efficient than the current process.

103. Social Security Scotland’s Local Delivery staff will provide support to applicants in rural areas. This will be an improvement on the current level of support offered through the Department for Work and Pensions system.

104. In line with the case transfer principles, clear and timely communication in relation to the transfer of Attendance Allowance awards to Pension Age Disability Payment will be provided. Individuals will not be required to reapply when their case transfers to Pension Age Disability Payment from Attendance Allowance. Their current award will be honoured with no break in payment to minimise disruption and ensure that people are paid the right amount at the right time.