Scottish Carer's Assistance: consultation

Impact assessments

In our work to develop policy for Scottish Carer's Assistance we have considered how the decisions we make could affect different people and groups differently – using research and evidence we already have, and continuing to listen to carers and organisations who support them to find out more.

It is important that our benefits are designed and developed in a way that works for all of Scotland's carers and the people and organisations that support them. We also want to do what we can to improve equality through Scottish Carer's Assistance and avoid any negative impacts on any people, groups, communities or businesses.

We would therefore like to use this consultation to take your views on any possible impacts Scottish Carer's Assistance may have in a number of areas that we may not have considered to date. A summary of what we have learned so far is provided below.

Equality Impact Assessment

An Equality Impact Assessment means thinking about how a policy could affect different groups differently when it is being developed, as well as thinking about how any proposed changes could be used to improve equality. In developing the proposals we have set out in this document we looked at equality information about unpaid carers to identify where changes could affect some groups more than others, either positively or negatively, and where there are opportunities to make changes which would improve equality.

The gendered nature of caring is one of those areas. Reflecting that in society caring roles most typically fall to women, 69%^[78] of people who get Carer's Allowance are women. Women already face a gender pay gap and are more likely to have been affected by previous benefit changes^[79], and by the coronavirus pandemic in multiple ways^[80]. Women are also more likely than men to rely on social security, and for some women, Carer's Allowance, paid directly to the carer, may be their main or only independent income. Increases to payment levels will help address financial inequality, but we also need to look more broadly. We know that people with intensive caring roles are more likely on average to have poorer educational, economic and health outcomes than their peers without such roles. So, changes which can provide more income stability for carers, and address barriers to education and employment, can also have a positive impact on women. To inform our proposals for future changes to Scottish Carer's Assistance eligibility criteria, we included equality as a factor within the formal analytical assessment process, the 'Multi Criteria Analysis' (more information on this process is provided on our website^[81]).

As Scottish Carer's Assistance is an income replacement benefit, mainly carers of working age will benefit. There is a small number of pension age carers who will receive it, and a significant proportion, around 39,400 as of August 2021^[82], of pension age carers have underlying entitlement. Underlying entitlement provides access to additional payments for carers on low incomes. These can increase the amount of support they receive by £37.70 a week (2021-22 rates).

Because of the close relationship between carers and the cared for person, we expect improvements we make in social security support for carers to have a disproportionately positive impact on the disabled people being cared for, many of whom will also be over pension age. However, our work to date has also identified the high proportion of carers who are themselves disabled^[83]. We will be very careful to ensure that their voice is heard in policy development so that Scottish Carer's Assistance meets their needs. This includes work with our Experience Panels, and, for example, we plan to carry out a bespoke piece of work with carers with learning disabilities as part of this consultation.

We know that for some ethnic minority groups, in addition to the lower awareness of the social security support available, there can be a range of barriers. For example language barriers, where the language used may be difficult to translate or has negative cultural resonance^[84]. A take-up barrier specific to carer benefits is that many people do not identify as carers. This can be the case for any carer, but we recognise that for some communities – including gypsy traveller and carers of south east Asian heritage – this may be particularly likely. We will undertake a programme of work with carers from these backgrounds to deepen our understanding of this issue, and identify practical actions to address it.

Work done by Social Security Scotland and through our 'Seldom Heard Groups' research to understand the needs of particular communities for all of our benefits will feed into the design of Scottish Carer's Assistance and how we promote it. We will build on what we have learned from Carer's Allowance Supplement and Young Carer Grant. We are also engaging with a diverse range of carers in our Experience Panels work and User Research to identify how we can design Scottish Carer's Assistance to be easy to access for all of those who would be eligible. Our work to link carers to further financial support they may be entitled to both from Social Security Scotland, and help from other organisations, particularly at key changes in the caring relationship, also has the potential to help address inequality.

We recognise there are areas where we lack equality information. For Carer's Allowance, only information on gender and age is gathered. In line with our practice across all of our benefits, we will collect a broader range of equality information for Scottish Carer's Assistance. This will help us understand the reach of the benefit, different experiences of the benefit, and where we need to take further proactive action. We will also use targeted events as part of this consultation to improve our understanding needs of particular groups where we lack sufficient information, such as faith communities and LGBT+ groups.

Question 44: Please set out any information you wish to share on the impact of Scottish Carer's Assistance on groups who share protected characteristics.

Island Community Impact Assessment

This is about testing any new policy, strategy or service which is likely to have an effect on an island community which is significantly different from the effect on other communities.

We are aware that island stakeholders have emphasised the importance of policy makers understanding the island experience. Each island has its own specific considerations and constraints, and there are several factors which impact on island residents' daily lives compared to people who live on the Scottish mainland.

When looking at the demographics of island residents compared to those who live on the mainland, the key notable demographic difference we have identified is age. Remote rural areas have a higher (25%) proportion of older people (65+) than the rest of Scotland (18%)^[85] - 62% of island residents are aged between 16 and 65, with the median age being 45, which is higher than the average across Scotland as a whole (41)^[86].

Citizens Advice Scotland^[87] has identified issues with the power grid, utilities, digital and travel as key barriers for people in accessible rural, remote rural and remote small towns, and we know that many costs can be higher on average^[88]. A lack of accessible employment, education and leisure opportunities can be made more difficult for someone with mobility issues and those who care for them, especially when transport options are limited. This shows us the value of pursuing options which improve the financial situation of unpaid carers in island communities. It will be important to make sure carers can be linked to services and support which may be of help to them through Social Security Scotland Local Delivery teams.

We have also heard that there are potential cultural barriers for island residents applying for Scottish Carer's Assistance, due to the close-knit nature of island communities. There is evidence of the positive impact of the support provided by close-knit communities^[89] (for example, neighbours and family members assisting with providing transport, as mentioned above). However, certain barriers may also be present, and some people may be reluctant to come forward for support from Scottish Carer's Assistance due to not wishing to disclose disability or caring status in the community. We will need to be sensitive to this in how we provide and promote our new benefit.

When Scottish Carer's Assistance is launched, Social Security Scotland's Local Delivery function will provide support to applicants in rural areas. This will be an improvement on the support offered through the current system. Local delivery officers will share locations with other services so that they are based where people currently go, to ensure that they can access advice and support. Access to support will be less reliant on digital methods for applications, reporting changes, and getting advice, which is of particular importance in remote rural and island communities in light of problems getting online.

Monitoring the impact of Scottish Carer's Assistance in island and remote rural communities will be a continuous process. We will put in place a monitoring and evaluation plan for Scottish Carer's Assistance prior to implementation which will take account of the issues identified within the completed Island Communities Impact Assessment. On-going stakeholder engagement with key carer organisations will also provide us with an opportunity to monitor the impact of the policy.

Question 45: Please set out any information you wish to share on the impact of Scottish Carer's Assistance on Island communities.

Fairer Scotland Duty

This is about looking at how the decisions we make about future policy for Scottish Carer's Assistance can help to reduce the challenges that people can face as a result of 'socio-economic disadvantage' – which can be things such as having a low income, not having access to basic goods or services, or having a background which gives them fewer advantages.

In making decisions about the proposed changes to Scottish Carer's Assistance we looked at which groups of carers would be most affected and which changes were likely to target lowest income carers or carers at greater risk of poverty. We already know that households with a disabled person are more likely to be in poverty, and these families, targeted by our Tackling Child Poverty Delivery Plan, may benefit from the changes we are proposing^[90].

Households with a Carer's Allowance recipient are more likely to be in poverty than the average household^[91] and they consistently tend to be in the bottom half of income distributions. In looking at the impact of policy proposals, it is important to consider the specific group of carers within the overall group who are likely to benefit. In particular, working age carers are more likely to be affected by poverty than carers aged 65 and over^[92].

It is estimated that around 90%^[93] of Carer's Allowance recipients live in a household with a disabled person (this may be themselves, the person they care for, or someone else). And, we know that poverty is more likely to affect disabled people. It is estimated that around 11.5% of households in receipt of Carer's Allowance are lone parents,^[94] and single mothers in particular have one of the highest poverty rates among the groups for which it is reported - 38%^[95] compared with 19% in the population, and the highest rate of child poverty of any group, also 38%^[96].

One of the first changes we made with our new social security powers was to increase Carer's Allowance by 13% through the Carer's Allowance Supplement. This was because Carer's Allowance was the lowest of all working age benefits. The payment is currently paid every six months to people in receipt of Carer's Allowance. We know through the Carer's Allowance Supplement evaluation^[97] that some recipients appreciate having the payment as a lump sum, however, for those carers on the lowest incomes, this made it difficult for them to use the money for ongoing basic living costs. A question on how to integrate the Supplement into Scottish Carer's Assistance is included earlier in this document.

Taking over all aspects of the benefit policy and delivery through Scottish Carer's Assistance gives us the opportunity to further increase the incomes of those carers who have amongst the most intense caring roles, and who on average are more likely to be on lower incomes.

We have proposed a new extra payment for people already eligible for Carer's Allowance, through the Carer's Additional Person Payment, and we propose to extend support through longer 'run-ons' of payments when there are changes which affect the person being cared for. We are also proposing to help improve unpaid carers' incomes for the immediate and longer term by addressing barriers to education and employment. As well as work to better link carers to practical support and services to help them, we propose increasing the earnings threshold and removing the current study restrictions.

Our formal process to assess options for changes to eligibility criteria further underlined that providing a new payment to carers with only underlying entitlement to Scottish Carer's Assistance would have minimal impact on poverty. Key information about impacts on poverty of our proposals is included in the relevant sections of this document.

One of the overarching aims for Scottish Carer's Assistance is to maximise benefit take up. The importance of this is reflected in one of our three aims for Scottish Carer's Assistance: 'Scottish Carer's Assistance is designed to ensure carers have a positive experience of the social security system, and to maximise carers' take-up of all support available to them'. An estimate of take-up of existing Carer's Allowance is not available due to the measurement limitations of the eligible population. As such it is not possible to assess how our proposals increase take-up of the benefit in a measurable way, but work to better understand and address challenges of particular communities more likely to be in poverty will be pivotal in increasing access. Our overall approach is set out in our benefit take-up strategy^[98].

In developing detailed policy for Scottish Carer's Assistance, we will be looking further at how it could do more to help tackle the disadvantages people face because of financial and economic inequality – in how it is designed, delivered, and communicated – and we would welcome views on this.

Due to our reliance on survey information we are limited in our ability to evaluate policy outcomes around poverty. However, as we start to deliver Scottish Carer's Assistance, we will have access to earnings information for carers, and will consider further actions needed to effectively evaluate the impact of our policies on poverty.

Question 46: Please set out any information you wish to share on the impact of Scottish Carer's Assistance on reducing inequality caused by socio-economic disadvantage.

Child Rights and Wellbeing Impact Assessment

The Scottish Government wants to make Scotland the best place in the world for a child to grow up. Recognising, respecting and promoting the rights of children and young people is essential to achieving this. We are taking steps to ensure that children experience their rights, as determined by the United Nations Convention on Rights of the Child. A Child Rights and Wellbeing Impact Assessment helps ensure that our policies, measures and legislation protect and promote the wellbeing of children and young people. A child is defined as anyone under the age of 18 as per the United Nations Convention on the Rights of the Child.

Scottish Carer's Assistance will be available to carers aged 16 and over so we would expect the primary impacts of Scottish Carer's Assistance to be on young people aged 16 and over. We would also expect to see an indirect positive impact for children and young people who are cared for by someone in receipt of Scottish Carer's Assistance or living with someone who receives Scottish Carer's Assistance.

According to 2011 Census data, around 8,200 (16-18) year olds provide some hours of unpaid care^[99]. As of May 2021, there were around 81,300 carers in receipt of Carer's Allowance in Scotland, of whom 420 were aged under 18^[100]. Full data on the numbers of children and young people who are cared for, or living with someone in receipt of Carer's Allowance, is not available.

Evidence also shows that young carers have poorer physical and mental wellbeing than non-carers. A survey by Carers UK from 2021 found 64% of carers of all ages said their physical health had worsened and 69% reported that their mental health had worsened as a result of their caring role^[101]. It was also found that 81% of carers of all ages have felt lonely or socially isolated as a result of their caring role. Within this, a larger proportion of younger carers reported feeling isolated. 31% of carers overall said not being able to afford to participate in social activities made them feel lonely or socially isolated^[102]. Young Carer Grant, the first benefit of its kind in the UK, was launched on 21 October 2019 to help address some of these issues for young carers aged 16, 17 and 18.

We expect Scottish Carer's Assistance to have a direct or indirect positive impact on the following articles of the United Nations Convention on the Rights of the Child:

Article 23 (children with a disability). Many children and young people with a disability may be cared for by people in receipt of Scottish Carer's Assistance. Eligibility criteria for Scottish Carer's Assistance will require that the cared for person is in receipt of specific disability benefits. The income replacement that Scottish Carer's Assistance is intended to provide support to these carers which should have an indirect positive impact on those they care for.

Article 26 (social security). Young people aged 16 and over who receive Scottish Carer's Assistance should be supported on a consistent basis to allow them to continue caring, if that is their wish, in good health and wellbeing while also allowing for a life of their own outside of caring. Our work to promote awareness and understanding of Scottish Carer's Assistance will also consider how best to reach young people who are entitled to this support. We are also proposing a future change to Scottish Carer's Assistance eligibility which would allow carers to study full-time and receive support. This is expected to benefit young carers in particular and could remove barriers to education for young carers, or support them to stay in education longer.

Article 42 (knowledge of rights). As part of the implementation of Scottish Carer's Assistance and the wider devolution of a number of social security benefits we will continue to work on increasing awareness and take up of benefits. We will also need to ensure that children and young people being cared for by people receiving Scottish Carer's Assistance and Carer's Additional Person Payment, or named on applications, receive appropriate information about this, and their rights in relation to this.

The relevant wellbeing indicators for this policy are:

Healthy: Scottish Carer's Assistance is intended to help improve the health and wellbeing of carers by supporting them to continue their caring role if they wish. This could have a positive impact on the health of young people who are receiving Scottish Carer's Assistance or children and young people who are cared for by those in receipt of Scottish Carer's Assistance.

Active: Scottish Carer's Assistance is being developed to also support carers to access opportunities outside of their caring role. We expect the payment to have a positive impact on young people in receipt of Scottish Carer's Assistance from this easier access to non-caring opportunities.

Included: Scottish Carer's Assistance is intended to provide additional support for carers to help them in their role, addressing inequalities they may face as a result of caring – for example, carers may be less able to take on paid employment or studies.

The positive impact of Scottish Carer's Assistance will be reduced if young carers do not receive the support they are entitled to. Research on young carers indicates that young carers may often not recognise themselves as carers – and as such may be less likely to receive support for their caring role. Promotion of Scottish Carer's Assistance will be used to mitigate this reduction, making sure carers know about what support is available to them. This issue along with the others highlighted will be taken into consideration in the planning of the promotion of Scottish Carer's Assistance to maximise the positive impact.

Having control of the benefit policy and delivery of Scottish Carer's Assistance gives us the opportunity to further increase the positive impacts those under the age of 18 years. Through measures like addressing barriers to education and employment, or by making it possible for carers to add together hours of care to meet the threshold we can remove some of the barriers to application for young people.

Question 47: Please set out any information you wish to share on the impact of Scottish Carer's Assistance on children's rights and wellbeing.

Business and Regulatory Impact Assessment

A Business and Regulatory Impact Assessment is used to analyse the cost and benefits to businesses and the third sector of any proposed legislation or regulation, with the goal of using evidence to identify the proposal that best achieves policy objectives while minimising costs and burdens as much as possible.

We have considered the potential business and third sector impacts of introducing Scottish Carer's Assistance, including Carer's Additional Person Payment. Creating a new benefit, widening eligibility, and changing some elements of how the benefit works, is likely to mainly affect carer support services and welfare advice agencies, as carers adapt to the new Social Security Scotland system and eligibility requirements, and consider applying for the new support. We will work with stakeholders from a range of organisations to ensure that we provide information and support in advance of Scottish Carer's Assistance launch and future changes in order to reduce these impacts. We published our second Benefit Take-Up Strategy in October 2021 under the provision of the Social Security (Scotland) Act 2018. The strategy sets out Scottish Ministers' work supporting benefit take-up to date. It also introduced a series of new activities and initiatives aimed at increasing awareness of and access to Scottish benefits and supporting those who are eligible to apply. These include new funding streams for benefit take-up and income maximisation.

We also considered potential impacts on legal aid, and do not consider it is likely to increase the number of people requiring use of legal aid, given the likely rate of challenges to decisions about Scottish Carer's Assistance eligibility.

Question 48: Please set out any information you wish to share on the impact of Scottish Carer's Assistance on businesses.