Mental health and wellbeing delivery plan: equality impact assessment

Chapter 4: Conclusion

This EQIA has shown that the broad principles and policies set out in the Strategy and the Plan will be positive across many protected characteristic groups, in particular for people from minority ethnic communities, LGBTI+ communities, people with disabilities and women & girls.

Actions are grounded in evidence of what the key cross cutting mental health inequalities are. Addressing these inequalities is strongly correlated to the priorities set out in the Plan.

For some particular protected characteristics, including race, sex, disability, sexual orientation and gender reassignment, higher levels of the causes of mental health inequalities exist. Therefore, wider action to reduce mental health inequalities will be beneficial to these groups in particular. This will result in a strong potential for the plan to contribute to reducing discrimination and enhancing equality of opportunity.

Whilst the plan has limited focus on fostering better relations between people of different protected characteristics, the focus throughout the plan on addressing stigma and discrimination, should support this objective.

We have found no evidence of negative consequences for protected characteristic groups at this time. However, in line with best practice this will be kept under review as part of our monitoring of this EQIA.

Individual EQIAs have already begun and will be taken forward on each of the strategic actions within the Plan. Some actions included in the plan are high level policies and proposals which are only partially defined. As these actions develop their EQIAs should ensure that specific barriers for each protected characteristic are fully considered.

The Equality Evidence Report provides a robust summary of the current evidence for both protected characteristic and marginalised groups mental health experiences. This should be both a helpful aid to developing EQIAs and lead to more specific and targeted engagement with stakeholders. We will regularly review the evidence and update the Mental Health Equality Evidence Report.

The Strategy has committed to put appropriate governance arrangements in place to oversee implementation and support progress of the Plan. These will be established during the first year of the Plan.

We will establish a new Mental Health and Leadership Board to oversee progress. The Board will provide national leadership and strategic oversight of priorities; ensure activity delivers clear benefits; provide constructive support and challenge to ensure progress of actions and play a key role in evaluating the impact of interventions and sharing learning.

The Board will have direct access to advice from key groups, including the Equality and Human Rights Forum and the Diverse Experiences Advisory Panel. This will seek to ensure that the interests of protected characteristic and other marginalised groups are represented and that progress towards tackling mental health inequalities is monitored.

Summary of recommendations:

Many actions within the Plan are high level. There is a risk that this may lead to a lack of work to address the specific needs of particular groups within action implementation. To mitigate this we produced the Equality Evidence Report to aid undertaking robust EQIAs of actions and ensure specific barriers for each protected characteristic group are fully considered and addressed. We have also included an 'Inequality Action Table' within the Plan (Appendix 1) to highlight where certain actions have an impact on key inequalities, and the groups most impacted based on evidence. The Plan states that delivery leads and delivery partners should give due consideration to these groups when scoping, planning and implementing these actions. This EQIA recommends that robust EQIAs should be carried out on each action as early as possible to ensure that specific barriers for each protected characteristic group are fully considered. The Leadership Board should have a role in monitoring these EQIAs to ensure specific issues are being addressed.

The Mental Health Equality Evidence Report is the largest collation of Scottish and UK wide evidence on mental health experiences of protected characteristic and other marginalised groups. Extensive consultation with people with lived experience, and our Equality and Human Rights Forum, informed the Report. Whilst it is important to continue to engage with these groups in the further development and implementation of policy we also acknowledge the strain of over reliance on the third sector and those with lived experience for evidence and the potential for consultation fatigue. This EQIA recommends therefore that delivery leads and partners should use the Report as the basis for undertaking robust EQIAs and informing policy and that further consultation with these groups is strategic, proportionate and informed by and building on existing evidence.

The EQIA and the Report highlight how wide-ranging the causes of mental health inequalities are. Recognising the limitations of time and resources, the Plan articulates its strategic approach to focus attention on improving equality of access to and experience of mental health support and services, with a specific focus on actions under priorities 4 and 7. Working closely with the Equality and Human Rights Forum and people with lived experience to develop, test and learn from a good practice approach. This EQIA recommends this should include consideration of: how we can direct our resources for maximum impact; how we can best work with stakeholders, including the Equality and Human Rights Forum and people with lived experience in a way which is constructive and proportionate; and how we can develop and deliver actions in a way which will have maximum impact on drivers of inequalities; considering the need for an intersectional approach and the needs of specific groups.

The Strategy sets out its commitment to appropriate governance arrangements including the establishment of a new Leadership Board which will have direct access to advice from the Equality and Human Rights Forum and Diverse Experiences Advisory Panel. This EQIA recommends membership of these groups should be reviewed to ensure appropriate representation and expertise.

A plan for how the Forum will work with the Leadership Board should be developed, ensuring that they can have appropriate influence on the support; challenge and monitoring of impact of the Plan on mental health inequalities, eliminating unlawful discrimination, advancing equality and opportunity and fostering good relations between those with protected characteristics.

For some actions in the Plan, evidence on actual or intended impact on people with protected characteristics is limited. This EQIA recommends as part of the overall monitoring and governance for this plan, greater focus should be placed on gathering, analysing and using data on impact to inform future policy design and delivery. This should include as close to real time monitoring as possible to quickly identify and remedy any unintended consequences.

Recognising the limitations of quantitative data, this EQIA recommends we should further strengthen the collection and use of qualitative data through existing channels, particularly for protected characteristic groups in regards to their experiences of services and support. Particularly in the areas highlighted as having a lack of data by this EQIA.

Next Steps

The Mental Health and Wellbeing Leadership Board will review the recommendations of this EQIA at their earliest convenience and if accepted will monitor their implementation.