Self-Isolation Support Grant: equality impact assessment

Equality Impact Assessment - Self-Isolation Support Grant

Name of Grant: Self-Isolation Support Grant (SISG)

Policy Lead: Carolyn Armstrong

SG officials/Author/Contributors

Nicola Pringle, Spencer Thomson, Carolyn Armstrong, Jim Ross, Eleanor Smith

Directorate: Directorate for COVID Business Support & Resilience

New policy / legislation

Creation of new policy, followed by several policy iterations to address impacts of covid. Establishment of Covid-19 Grant, followed by several grant eligibility iterations to address impacts of covid and inequalities.

Legislative Power

The SISG sits inside the Scottish Welfare Fund (SWF). The SWF is a national scheme, underpinned by law, The Welfare Funds (Scotland) Act 2015 ("the Act")^{[1, 2]} and delivered on behalf of the Scottish Government by all 32 local authorities. The SWF is the legislative and delivery mechanism for SISG in the form of Crisis Grants, It aims to provide a safety net to people on low incomes by the provision of Crisis Grants and Community Care Grants.

The Act places a statutory responsibility on each local authority to maintain a Welfare Fund^[3]. The Act also gives powers to Scottish Ministers to make regulations and publish guidance, setting out how these funds should be administered. The Welfare Funds (Scotland) Regulations 2016 ("the Regulations") and this guidance were subject to public consultation (between 27 May 2015 and 21 August 2015). The guidance is reviewed annually and is issued by Scottish Ministers under Section 6 of the Act.

During the Covid-19 pandemic, it has been necessary to amend eligibility for the SISG on different occasions. Therefore the SWF guidance is maintained on an on-going basis and is updated and shared with local authorities as and when changes have been required.

Grant Overview

The Scottish Government is committed to providing a Self-Isolation Support Grant (SISG) of £500 to workers who earn less than the Real Living Wage or are in receipt of a low income benefit, and who will experience reduced earnings as a result of them, their child or the person they are caring for being required to self-isolate to prevent the spread of COVID-19.

This grants help to support people who would otherwise struggle to be able to afford to comply with the requirement to self-isolate. It provides them with the financial support they need to meet their basic needs during the 7-day period in which they are unable to work.

Executive Summary

The Government has been clear since the beginning of the Covid-19 pandemic that Self-isolation was, and continues to be, an essential tool in reducing the spread of Covid-19. With this in mind, the SG took the necessary steps to provide financial assistance for those groups of people who would otherwise find it difficult to self-isolate when required to do so.

In developing this fund the Scottish Government is mindful of the three needs of the Public Sector Equality Duty (PSED) - eliminate unlawful discrimination, harassment and victimisation, advance equality of opportunity between people who share a protected characteristic and those who do not, and foster good relations between people who share a protected characteristic and those who do not - and recognises while the measures may positively impact on one or more of the protected characteristics^[4]. Where any negative impacts have been identified, we have sought to mitigate/eliminate these. We are also mindful that the equality duty is not just about negating or mitigating negative impacts, as we also have a positive duty to promote equality. We have sought to do this by designing the grant so the eligibility criteria of the grant allowed us to include as many groups as possible.

Delivery of a Self-Isolation Support Grant needed to be achieved quickly, and be deployed and supported from within the existing public administration infrastructure. A simple claim process was established by adapting the existing SWF processes, which were already consistent with existing compliance standards.

The Scottish Government understands the impacts of COVID-19 have been, and will continue to be, experienced disproportionately by different groups, including women, those from minority ethnic communities, older people and disabled people which is why £4.4 billion has been committed to providing financial support. This emergency funding has supported otherwise strong and viable businesses, protecting the business base, jobs and people's livelihoods - helping prepare for a stronger economic recovery.

In order to address the needs of many sectors adversely impacted by the pandemic, a range of business supports and personal support fund were introduced quickly, over several months, to provide emergency funding to help secure jobs, safeguard businesses and to alleviate financial personal hardship. Self-isolation Support Grant was one such fund.

SISG development has aligned with SG Health policy, who lead on the emerging developments of Covid Policy. SISG development was originally housed within the Fair Work Directorate, given the support lay with businesses and economic impact, but given the growing scale and impact of Covid-19 across the economy, a bespoke Directorate was established in February 2021– COBRAS (Covid Business Resilience and Support) – to develop resilient and targeted economic support.

Eligibility for the grant is restricted to those low income workers or parents/guardians who have been notified by Test and Protect or an incident management team or those who are not fully vaccinated. Before the self-isolation period, they must also be:

• employed or self-employed
• unable to work from home, and will lose income as a result of self-isolation
• be assessed as having low income, either
• the household is currently receiving, or has been awarded, but not yet received, a payment of the following benefits; or whose income may entitle them to Universal Credit, should an application have been made prior to their isolation:
• Universal Credit, Tax Credit, Income-based Employment and Support Allowance, Income-based Jobseeker's Allowance, Income Support, Housing Benefit, Pension Credit and/or Means-tested Council Tax Reduction.
• be an individual who earns less than the Real Living Wage threshold

the household income is such that it falls within the agreed definition of 'low income' for this purpose; being 25% above the established UC rate for their household type in their local authority area.

The initial forecast suggested that, between October and March, around 22,600 people would be eligible for the Grant, at a forecast cost of £11.3m.

As of March 2022, we projected to be able to support 124,000 people in year 21/22, supported by a budget of £62 million.

Sources of data

The Scottish Government drew on a wide range of sources to understand the impact of restrictions on those with protected characteristics. These sources include statistics published by both the Scottish Government Economist (OCEA) and the Office of National Statistics, as well as insights from the Annual Population Survey and Equality Evidence Finder – a Scottish Government and its Agencies source to collect, analyse and publish equality evidence across a wide range of policy areas and equality characteristics. We also have access to information that is returned directly from LAs on SISGs, and information that the SG collects related to the Scottish Welfare Fund. As these sources of information have been collected over different time periods, they have been triangulated somewhat to allow us to get the best picture available on equalities data.

Every effort is made to ensure that Equality Impact Assessments (EQIA) are published timeously. However, the speed at which it was necessary to ensure mechanisms are in place for supporting the impacts of Covid-19 restrictions resulted in delays to completing EQIAs for a number of support funds, including SISG. We developed the monitoring tools to capture data, and memorialised policy changes and costs as each iteration was made to SISG.

SISG Iterations

SISG has undergone a number of iterations since it was launched on 12 October 2020.

1. 7 December 2020, the grant was extended to include:

• workers of families who are claiming Universal Credit (if they claimed it)
• Parents of children who are told to self-isolate
• Council can use exceptional circumstances for late applications

2. 20 November 2020, the grant was extended to include:

• Those who do not have Recourse to Public Funds (NRPF)
• This ensures the same rules apply to someone who is required to isolate but cannot access the funds via the Scottish Welfare Fund (SWF) due to their immigration status

3. 2 February 2021, the grant was extended to include:

• Those on Council Tax Benefit
• families not in receipt UC but within 25% of similar family
• Real Living Wage or lower

Extending the application period to 28 days from the point of being told to self-isolate.

4. 2 May 2021

• Due to an outbreak in Glasgow, eligibility was extended to secondary as well as primary contacts in certain postcodes.

5. From May 2021, the grant was extended to include

• seasonal workers from May 21.
• we explicitly created new guidance and the inclusion in the NRPF scheme.

6. In October 2021, the grant was amended to:

• to remove the need for fully vaccinated contacts to isolate as close contacts.
• The Grant was changed to support the health policy and to ensure those who were not isolating were not eligible for the Grant.

7. From 30 November 2021 to 10 December 2021, the grant was amended to reflect

• The health policy changed to support the increase in the Omicron variant.
• Omicron was added as a variant of concern for the purpose of the Grant
• Eligibility was changed for vaccination and household status are irrelevant as all contacts are required to isolate

8. From 11 December 2021 to 5 January 2021, the grant amended to

• apply the household contact rules – vaccination status is irrelevant for household contacts, but relevant for non-household contacts

9. From 6 January 2022 onwards

• apply the fully vaccinated rules – only positive cases and contacts over the age of 18 years and 4 months old who are not fully vaccinated are eligible.

Age: Children and Young People

Children and young people can be affected by self-isolation, and therefore the provisions of this grant in two ways. Firstly, the children and young people may themselves require to self-isolate if they test positive (Children and Young People under the age of 18 are exempt from the requirement to self-isolate, where they are identified as a close contact of someone who has tested positive and have returned a negative PCR test).

Children and young people may be affected by others in their household having to self-isolate, parents or carers in particular. If those others self-isolating lose income as a result, that could impact on the children and young people's wellbeing and welfare, particularly in low income households.

In lower income households in particular, financial losses could dis-incentivise compliance with self-isolation. Many working parents do not have the backup of contractual employment arrangements that allow them to be paid while looking after isolating children. The children and young people, or those in their households, may be under pressure to continue working despite being asked to self-isolate, which risks the further spread of the virus and impacting on the health of those in the household, potentially magnifying the losses.

Children were being sent to school, even though they were told to isolate as contacts. This resulted in major Covid-19 transmission problems in schools and the wider community.

In the third report of Public Health Scotland's COVID-19 Early Years Resilience and Impact Survey, it was found that, in 3 out of 10 households, the status of the main household earner had changed as a result of economic changes post-lockdown, and 4 out of 10 households had seen their income reduce. This highlights the wider socio-economic impact that children face, as a result of the impact of isolation on their parents and wider concerns on the fall-out of weaker economic activity.

The wider impacts of this can be significant on children and young people, either on their own employment if they are older teens or through the impact on their parents, can be significant. For the former group, it can lead to significant reduced income and impact precarious employment when they are starting out in the workplace. For the latter group, it can have significant impacts on the household – either through dis-incentivising compliance and the attendant health consequences or through wider impacts of a drop of income on the wellbeing of parents, carers or children.

For this reason, ensuring that the current self-isolation support grant can continue for lower income parenting groups is a priority. This is achieved through continued funding of the grant into next financial year, and through the Coronavirus (Discretionary Compensation for Self-Isolation) Bill. Through ensuring Health Boards do not face a liability of £380 million by keeping the current modification in place to the Public Health etc. (Scotland) Act 2008 - which suspends the obligation on Health Boards to provide compensation to people who are self-isolating due to coronavirus - resources can remain to support their pandemic response and urgent care.

In developing this fund, the Scottish Government is mindful of the three needs of the Public Sector Equality Duty (PSED). The Scottish Government has sought to address the impacts above – SISG is tailored financial support for anyone notified to isolate who earns the equivalent of the real living wage or less. Please see the PSED section later on in this document. By ensuring this support remains towards those on low incomes, this policy supports children and young people in low income households (or on low incomes) who may be impacted.

In the last 15 years, the youngest adults (16-24 year olds) have been consistently more likely to be in relative poverty compared to older adults.^[5]

In 2017-20, 28% of adults aged 16-24 were in relative poverty after housing costs (140,000 adults each year), compared to 15% of adults aged 65 and older (150,000 adults). The age groups in between all had similar poverty rates between 17% and 19%.

From figures provided by the collection of data from local authorities, from October 2020 to November 2021, 34% of SISG applicants were aged 16-24.

With regards to information available, 217 awards were made to carers out of 46,040 awards in total to the end of Nov 2021. Our information on acceptance rate is incomplete and no additional information is currently available.

Older People

Older people who are in work in low-income jobs face losses if required to self-isolate, but no more so than any other age group. We additionally have a requirement for carers of older people who are unable to isolate unassisted. With the prevalence of the virus higher in older people, those who are working are at a disadvantage with a higher risk of requiring to self-isolate. SISG was designed to reflect the needs of these groups and mitigate financial loss.

Among single pensioners, a slightly higher proportion of women than men were in poverty in 2016-19 (18% vs 15%). This may partly be due to their different age profiles.^[6]

In 2017-20, 20% of single female pensioners (50,000 women each year) and 17% of single male pensioners were in relative poverty after housing costs^[7]. Note that there were too few single male pensioners in poverty in the sample to produce a robust estimate of their population.

In most years, the poverty rate after housing costs for single female pensioners had been higher than that for single male pensioners, with this gap only recently widening and closing again.

Some of the difference in pensioner poverty between sexes may be due to different age profiles. For example, in 2017-20, 40% of female single pensioners were aged 80 or older compared with 30% of male single pensioners. Older pensioners may have different sources of income which may result in them having lower incomes.

Sex: Men

There is no evidence to suggest men are impacted any differently as a result of their sex. No differential impacts are identified. The poverty rate for single men without children was 34% (90,000 men). Estimates for single fathers are not available due to small sample sizes.^[8]

Women

There is evidence that women have experienced financial detriment as a result of self-isolation. Women are more likely to be an unpaid carer than men, with 27 per cent of women providing unpaid care reporting that caring duties impacted their employment. During the first lockdown, mothers were 1.5 times more likely than fathers to lose or quit their jobs to cope with unpaid caring responsibilities.^[9]

In 2016-2019 combined, 27% of women who provide unpaid care say that this has impacted on their employment:

• 7% were unable to take up work
• 10% worked fewer hours
• 5% left work altogether
• 2% took early retirement.

Over a third of women who are carers said that they experienced a negative impact on their health and wellbeing in 2017-18.^[10]

Carers UK estimate that the number of unpaid carers has increased in the UK by 50% as a result of the pandemic, bringing to total to 13.6 million. Women are more likely to be providing this care.^[11]

The poverty rate was highest for single women with children (38%, 40,000 single mothers each year). The poverty rate for single women without children was 27% (60,000 women), and for single men without children was 34% (90,000 men). Estimates for single fathers are not available due to small sample sizes. The minority ethnic employment gap is much higher for women (22.0 percentage points vs 9.5 for men, in 2019).^[12]

Until 2010-13, the gap in poverty rates between these groups had narrowed, but in recent years it widened again.

90% of lone parents are women, and are more likely to be living in poverty, so there is a gendered aspect to the impact of the pandemic and the measures to combat it^[13]. Women, in addition to being more likely to live in poverty, may be forced to choose between childcare/care for elderly relatives, health and safety and going to work^[14].

There are now 1.1 million unpaid carers in Scotland, 61% of whom are women. This is an increase of 392,000 since the start of the crisis with 78% of carers having to provide more care than they were prior to the coronavirus outbreak.

As a result, women who are unpaid carers are more likely to be in less secure, lower paid work or to be unemployed. Under Section 58 of the 2008 Public Health Act, carers who suffer loss as a result of the person they care for being asked to self-isolate (such as parents) would ordinarily be entitled to compensation, This Coronavirus (Discretionary Compensation for Self-Isolation) Bill (and the UK Act before it) suspends this. This means that compensation is not mandatory.

From figures provided by the collection of data from local authorities, from October to November 2021, 55% of SISG applicants were women.

Race

Minority Ethnic people are more likely to work in low income professions and therefore more likely to be impacted by the requirement to self-isolate.

This is compounded by the modification to the Public Health etc.(Scotland) Act 2008 remaining in place. There are significant socio-economic inequalities that are faced by people from ethnic minority backgrounds. 39 per cent of people from an Asian or Asian British background face relative poverty after housing costs are removed in Scotland, with 38 per cent of people from a mixed, black or black British or other related background in the same situation. By contrast, for people identifying as "White-Other" that figure is 25 per cent and for those identifying as "White-British" that figure falls further, to 18 per cent.^[15]

In addition, in BME communities Bangladeshis and Pakistanis have much higher rates of heart disease compared to their white British counterparts, and black African and African Caribbean people have higher rates of hypertension compared to other ethnic groups^[16]. Further, BME groups overall are six times more likely to develop diabetes compared to white British people. There is substantial evidence to show that BME communities experience high rates of child poverty and ill-health.

In terms of the job market, a higher proportion of minority ethnic people work in the hospitality industry (31.7% vs 18.6% of the white population, 2019 data). According to the last census, Asian men and women were particularly likely to be working in wholesale and retail and accommodation and food services, and African women were by far the most likely to be working in either caring, leisure and other service occupations or sales and customer service occupations, where homeworking may be much less feasible.^[17]

There is also an intersectional challenge with the inequalities issues faced by minority ethnic women and young people. The minority ethnic employment gap was much higher for women than men. For women the gap was 22 percentage points and for men it was 9.5 percentage points. The gap in the employment rate for the minority ethnic population was largest for ages 16 to 24 (26.1 percentage points); followed by ages 25 to 34 (25.3 percentage points), ages 35 to 49 (15.0 percentage points), and ages 50 to 64 (3.1 percentage points). There was some evidence of possible negative differential impact, mitigated by SISG.

The data also supports that there is a higher percentage of multi-generational households in concentrated ethnic minority areas across Scotland. This results in increases to secondary contact transmission rates. In May 2021, eligibility for the grant had to be extended to secondary as well as primary contacts for certain postcodes with the Govanhill area of Glasgow due to a health requirement to deal with the large number of cases within those densely populated areas.

Ethnic minorities are more likely to live in 'overcrowded' housing as well as multigenerational households; 30% of Bangladeshi households and 15% of black African households are overcrowded (where there are more people than bedrooms), compared to 2% of white British households.^[18]

SISG support for self-isolation - £500 grant - to help anyone earning the equivalent of the real living wage or less to get through a period of isolation, including secondary contacts, mitigates the economic impact for BAME people in low-paid or insecure work.

In addition, the economic and social challenges faced by these groups – a higher likelihood of falling into poverty, an increased chance of being in a job that may bring workers into contact with COVID-19, the Self-Isolation Support Grant can mitigate the cost to workers from these backgrounds, who may be on lower incomes and below the real living wage, by providing targeted support to get them through a period of isolation. In addition, the assistance provided by the Local Self-Isolation Assistance Service enables the provision of vital support such as food and essential medicine delivery.

In 2015-20, people from non-white minority ethnic groups were more likely to be in relative poverty after housing costs compared to those from the 'White - British' and 'White - Other' groups.^[19]

The poverty rate was 41% for the 'Asian or Asian British' ethnic groups (50,000 people each year), and 43% for 'Mixed, Black or Black British and Other' ethnic groups (no population estimate available due to the small sample).

The poverty rate amongst the 'White - Other' group was 24% (80,000 people) and that of the 'White - British' group was 18% (860,000 people).

Disability

The Scottish Health Survey^[20], estimates that, in 2018, 33% of adults (and 12% children) in Scotland were disabled, defined as having a limiting long-standing condition.

The survey provides an accurate estimate of the number of disabled working age people in Scotland. For young people aged 16-24, 24% of young people have a limiting longstanding illness. This number raises to 30% for individuals aged between 25-34, 32% between 35-44, 46% between 45-54 and, finally, 60% between 55-64.

The proportion of adults providing unpaid care for a family member, friend or someone else remained at 15% among those aged 16 and over and 4% for children aged 4-15.

This same survey indicates that disabled adults are likely to fall into the lowest household incomes - in 2018, 51% of adults with household incomes in the bottom quintile (less than £14,300) were disabled, compared with 23% adults with household incomes in the top quintile (£49,400 and above).

Disabled people represent a third of all Scottish Adults, and half of all adults with household incomes are amongst those on the lowest incomes in Scotland. Without support in place, the impact of the modification would be to exacerbate already existing income inequalities faced by this group.

The current support for self-isolation, the Self-Isolation Support Grant, provides some mitigation for this. This Grant has always been targeted at those workers on low incomes who cannot work from home, and is currently available to people who are self-isolating, lose income, and earning the equivalent of the real living wage or less.

In terms of practical support, the Local Self-Isolation Assistance Service provides direct assistance which can support the needs of disabled people, alongside the wider population.

Above, the ONS figures highlight that almost a quarter of disabled people surveyed – more than double the non-disabled population, have required support with groceries, food and essential medicine delivery and the provision of essentials. This is the very service that the Local Self-Isolation Assistance Service provides, alongside social support or signposting to mental health support.

In 2017-20, the poverty rate after housing costs for people in households with a disabled person was 23% (500,000 people each year)^[21]. This compares with 17% (540,000 people) in a household without disabled household members.

Again in 2017-20, as in previous years, the poverty rate was higher for individuals in households with a disabled person, when disability-related benefits are not included in the household income. After housing costs, the poverty rate was 29% (640,000 people each year) for people living with a disabled household member, and 16% (500,000 people) for those without.

Religion and Belief

There is no evidence to suggest people from a faith (as opposed to a minority) background are adversely affected by the Self-Isolation Support Grant.

However, religion and belief became a consideration when we looked at the double vaccinated iteration. Our decision was to leave it at actually having the vaccination not being offered it because for some, it is a religious decision not to be vaccinated. It would be discriminatory to ask someone their reason/s for exemption and why they had not been vaccinated.

More generally,^[22] In 2015-20, Muslim adults were more likely to be in relative poverty (52%, 30,000 each year) than adults overall (18%), after housing costs were taken into account.

Of adults belonging to the Church of Scotland, 15% were in relative poverty after housing costs (170,000 adults each year), compared to 19% of Roman Catholic adults (110,000 adults) and adults of other Christian denominations (19%; 70,000 adults).

This analysis does not take into account differences in the age profiles of the religions.

For adults belonging to the Church of Scotland, the median average age was 62. In contrast, the median age was 36 for Muslim adults, and 41 for adults belonging to no religion.

Older adults have a lower poverty rate, so age profile partly explains the lower poverty rate for adults belonging to the Church of Scotland. However, the age difference cannot explain the entire gap in poverty rates between religious groups.

Due to the small sample sizes for some of the religious groups, and the fact that religious composition of the population is not accounted for in the survey weighting process, estimates fluctuate between years and the measurement uncertainty will be fairly large. A time series has not been produced for poverty rates by religion, as this uncertainty in the data will obscure any long-term trends. Similarly, the estimated number of adults in poverty is not available for some religious groups due to small sample sizes

Sexual Orientation

There is no evidence to suggest that people are adversely affected by the Self-Isolation Support Grant as a result of their sexual orientation.

Whilst our evidence on sexual orientation is limited, any measures which are designed to reduce the risk of infection should benefit everyone in society. Therefore it is anticipated that this funding should advance equality of opportunity by contributing to the reduction of risk and by promoting understanding of the health risks between people.

Pregnancy and maternity

Pregnancy is recognised as being a key trigger that increases the risk of women living in poverty^[23]. The experience of being pregnant and living on a low income can often place pressures on women during their pregnancy, including increased stress due to worry about additional costs.

When the SISG was created, we had no evidence to suggest that people could be adversely affected by the Self-Isolation Support Grant as a result of Pregnancy and maternity. Also, at that point in time, no Covid-19 vaccines were available. We now understand that vaccines play a vital part in protecting against severe disease and reducing pressure across the NHS.

The risk to pregnant women and new born babies following coronavirus (COVID-19) infection is generally low^[24]. However, some women may become seriously unwell and need hospital treatment, particularly in the third trimester. Pregnant women with coronavirus have a higher risk of being admitted to intensive than women of the same age who are not pregnant. Recent data in the UK shows that almost all pregnant women admitted to hospital with coronavirus with symptoms were unvaccinated.

The SISG does not adversely affect those who are pregnant or on maternity leave. Everyone who meets the eligibility criteria can apply for the SISG regardless of whether you are pregnant or on maternity leave or not.

Gender reassignment

There is no evidence to suggest that people are adversely affected by the Self-Isolation Support Grant as a result of their gender reassignment.

Marriage or Civil Partnership (employment only)

There is no evidence to suggest that people are adversely affected by the Self-Isolation Support Grant as a result of marriage or civil partnership.

In 2017-20, the relative poverty rate after housing costs was highest for single adults (27%, 260,000 adults each year) and divorced (or separated) adults (27%, 100,000). Married adults were the least likely to be in poverty (13%, 260,000), and widowed and cohabiting adults were in the middle (19% and 19%; 60,000 and 120,000).

Poverty among widowed and divorced/separated adults largely decreased over the long term, whereas the trend for singles, cohabiting and married adults was broadly flat over time.

The mitigations sections makes reference to the real living wage eligibility which whichwas brought in to address the disadvantage that second earners in households that were collectively above the low income threshold had. These second earners are more likely to be women.

Socio-economic disadvantage: any people experiencing poverty

As outlined in the background to this document, people on lower incomes or insecure work, without the protections provided by contractual or statutory sick pay, stand to be impacted the most from a requirement to self-isolate. As outlined in individual assessments above, this may also read across into intersectional considerations, such as the increased risk BAME or disabled people face with regard to being on lower incomes.

ScotCen Social Research were commissioned by the Scottish Government to carry out a mixed mode study of adults asked to self-isolate by Test and Protect either because they tested positive for COVID-19, were in contact with someone that tested positive for COVID-19 or recently arrived into Scotland from outside the UK^[25].

When analysed by levels of area deprivation, those living in the two most deprived SIMD quintiles were more likely to indicate that they had/were struggling financially (21%) compared with those living in the other three deprivation quintiles (8%).

Respondents who were index or contact cases living in the two most deprived SIMD quintiles were more than twice as likely to have applied for a self-isolation support grant compared with those living in the other three quintiles (13% and 5% respectively).

The distribution of lateral flow/LFD tests being reported varies substantially by both age and deprivation status, with many fewer tests reported in younger adults across all deciles of deprivation, and for children in more deprived deciles^[26].

Those with household incomes of less than or equal to £16,900 (17% across all three waves) and £16,901 to £30,700 (13% across all waves) were more likely than those with higher household incomes to have applied for a self-isolation support grant.

The weekly national summary of Scottish local authority support data covering 14 to 20 February 2022 highlights that the majority of contact was to provide individuals with financial support. Namely, 1,933 referrals to the Self-Isolation Support Grant, 369 referrals to other financial support, 236 people required assistance with food for financial reasons and 120 required assistance with food for access reasons^[27].

Stakeholder Engagement

There are many organisations representing people who are disproportionately affected and defined as having protected characteristics. The SISG EQIA is looking at the details of eligibility for the grant itself.

When the SISG was being established, there was limited opportunity to engage individually with these groups due to the urgency of the situation. SG officials had rapid and focused engagement with experienced Welfare Fund practitioners in late 2020 and are aware that the principles of holistic service provision and inclusive communication underpin the SWF.

Initially, a great deal of our stakeholder engagement came via insight into the grant from the volumes of correspondence we received from members of the public directly or via their MP or MSP. From this wealth of information we could identify particular issues that were occurring and needed to be addressed. For example we received large amounts of correspondence from parents/guardians who had to self-isolate, but were then ineligible for the grant, if the child they cared for had to be off school due to an outbreak in their class. As the grant developed, we had ongoing communication with local authority representatives and received invaluable feedback from them and via comments made on the mygov web pages.

Three needs of the Public Sector Equality Duty (PSED)

As set out in the Executive Summary, in developing this fund the Scottish Government is mindful of the three needs of the Public Sector Equality Duty (PSED) - eliminate unlawful discrimination, harassment and victimisation, advance equality of opportunity between people who share a protected characteristic and those who do not, and foster good relations between people who share a protected characteristic and those who do not.

The SISG fund supports measures that help limit the spread of coronavirus may particularly positively affect those with underlying health conditions (including people who are more likely to experience severe ill-health from contracting Covid-19 than the general population), protecting their health and helping to advance equality of opportunity.

The fund should help to mitigate any negative impacts of having to self isolate, and advance equality of opportunity, providing support for people who may be at risk and do not have community support available, as well as those who cannot get online. It may also have a positive effect in fostering good relations between people, as those administering the fund may have the opportunity to understand more about the difficulties faced by (disabled people, minority ethnic people etc) people.

Actions and decisions have been made on an on-going basis to address any adverse impacts of self-isolation identified on groups with protected characteristics. (Age, Sex, Race, Disability, Religion and belief, Sexual orientation, Pregnancy and maternity, Gender reassignment, Marriage or Civil partnership (employment only)).

After the grant was launched in October 2020, it quickly became apparent that there was an issue with parents/guardians of children being asked to self-isolate due to an outbreak at their school, not being eligible to apply for the SISG. This affected the protected characteristic of Age (children and young people) and Sex (Women) as women are more likely to work part-time and therefore to take time off to care for their children.

This ineligibility to apply for the fund posed a risk of already low-income families being financially penalised due to their child/ren having to self-isolate and their parent/guardian being unable to go to work. Due to the information we were receiving from our correspondence, we understood a change needed to be made to the grant to include an extension to pay parents of self-isolating children. This involved accessing LAs' education data to help us fully understand the numbers in question and to justify the extension.

As a result of this work and the action we took, eligibility for the scheme was expanded on 7 December 2020 to include: 1) parents or primary carers of children required to isolate; and 2) applicants who would ordinarily have an underlying eligibility for Universal Credit (based on earnings prior to the self-isolation request period), who experience a reduction in earnings as a result of being asked to self-isolate.

There was scope, on a discretionary basis, for retrospective revisions of decisions involving those parents or primary carers of children required to isolate who had applied prior to 7 December 2020 and were refused solely on that ground and indeed LAs did receive a number of these applications.

We also brought in discretion because early on PCR tests were not easy to get particularly for children so one of the discretionary provisions was specifically to address outbreaks in schools.

To ensure the protected characteristic of race was considered, in November 2020, the grant was also extended to help those who have no Recourse to Public Funds (NRPF). This change ensured the same rules apply to someone who is required to isolate but cannot access the funds via the Scottish Welfare Fund (SWF) due to their immigration status. The grant was extended further in May 2021 to include seasonal workers brought in via the Agricultural Seasonal Workers Programme which brings workers from around the world to the UK. At that point, we explicitly created new guidance and included in the NRPF scheme

In order to address on-going issues affecting the protected characteristics of age, sex, marriage and civil partnership and disability, eligibility for the scheme was expanded further on 16 February 2021 to include: 1) applicants who are in receipt of means-tested Council Tax Reduction; 2) applicants who earn the Real Living Wage or less or whose household income is less than Universal Credit + 25% for their circumstances; 3) carers of adults required to isolate; and 4) a widening of the application period to 28 calendar days from being told to self-isolate. Someone who had been told to self-isolate on or after 2 February 2021 (but before the extension is operational in their local authority area) would have been able to make a backdated claim for payment.

This further expansion of the eligibility criteria allowed for more claims to be made and to allow more individuals and families to access the financial support they needed to help them self-isolate without being financially penalised for doing the right thing to help protect themselves and others.

Eligibility for the scheme was then changed on 6 October 2021 to ensure that the definition of low income as less than Universal Credit + 25% for their circumstances was calculated to continue to include the £20 per week temporary coronavirus increase in the Universal Credit Standard Allowance.

When the Omicron variant became dominant late in 2021, eligibility for the scheme was changed further on 30 November 2021 to enable contacts of someone who has tested positive or has been asked to isolate as part of an exercise within the public health response to a variant of concern to be eligible if they had to isolate for the required 10-day period. Eligibility for the scheme was changed further on 11 December 2021 to enable identified household contacts of someone who has tested positive to be eligible regardless of their vaccination status if they have to isolate for the required 10-day period. These steps were taken to extend eligibility to ensure that those who were required to self-isolate had some financial support to allow them to do so.

As of 6 January 2022 eligibility for the scheme was changed further to require that individuals identified as contacts by Test and Protect (or equivalent service across the UK) who have been fully vaccinated become eligible only when they themselves test positive following public health policy's return to the isolation requirements prior to 30 November 2021. This includes children and young people under the age of 18 years and 4 months who are treated as fully vaccinated from this date.

This mitigation reduced eligibility, but was based on the scientific evidence available at that time, which showed that due to the success of the vaccination booster programme, which had been made available to a much wider section of the population, and as we learned more about the Omicron variant, we understood that the mitigations put in place in November 2021 were no longer necessary. The reduction in eligibility meant the grant fund available would be best spent on those identified as needing to self-isolate to stop the spread of Covid-19.

Although fully vaccinated (non-index cases) no longer have to self-isolate, prior to reducing eligibility, we checked to ensure those who are unvaccinated would not be unfairly discriminated against and this group remain eligible to apply for the grant.

Next steps

Before the COVID-19 pandemic, health boards were required to compensate people who they asked to self-isolate due to an infectious disease. This was required by the Public Health etc. (Scotland) Act 2008.

The Coronavirus Act 2020 changed this. The 2020 Act let health boards decide whether people who are self-isolating because of COVID-19 received compensation under the 2008 Act. The relevant provision of the 2020 Act expired in March 2022.

This Bill would change the law so that health boards will still have the option to provide compensation. However, they will not be obliged to do so, to anyone they ask to self-isolate due to COVID-19.

The law will apply until 31 October 2022. The Bill allows for the Scottish Government to reduce or extend that period if required. The Bill was passed on 09 February 2022 and became an Act on 23 March 2022^[28].

Review

In order to ensure any new mitigations of the grant are reflected within the EQIA document, it is our intention to review and republish as necessary within a six-month period.

Authorisation of EQIA

Please confirm that:

This Equality Impact Assessment has informed the development of this policy and subsequent iterations:

Yes X

No

• Opportunities to promote equality in respect of age, disability, gender reassignment, pregnancy and maternity, race, religion or belief, sex and sexual orientation have been considered, i.e.:
  • Eliminating unlawful discrimination, harassment, victimisation;
  • Removing or minimising any barriers and/or disadvantages;
  • Taking steps which assist with promoting equality and meeting people's different needs;
  • Encouraging participation
  • Fostering good relations, tackling prejudice and promoting understanding.

Yes X

No

• If the Marriage and Civil Partnership protected characteristic applies to this policy, the Equality Impact Assessment has also assessed against the duty to eliminate unlawful discrimination, harassment and victimisation in respect of this protected characteristic:

Yes

No

Not applicable X

Declaration and Publication

I have read the Equality Impact Assessment and I am satisfied that it represents a fair and reasonable view of the expected equality impact of the measures implemented.

I give my authorisation for the results of this assessment to be published on the Scottish Government's website.

Name: John Paul Liddle

Position: Deputy Director

Authorisation date: 27 April 2022