Scottish Carer's Assistance: consultation analysis

Impact Assessments

The consultation noted that in their work to develop policy for Scottish Carer's Assistance the Scottish Government has considered how the decisions made could affect people and groups differently. It highlighted that carer benefits will be designed and developed in a way that will help ensure that they work for all carers. The consultation also noted that the Scottish Government is seeking to avoid any negative impacts in benefit delivery to any people, groups, communities or businesses.

Equality Impact Assessment

The consultation paper noted that the Scottish Government has looked at equality information about unpaid carers to identify where changes could affect some groups either positively or negatively, and where there are opportunities to make changes which would improve equality.

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.

A total of 70 respondents answered this question. Some respondents provided general comments rather than referencing specific groups who share protected characteristics. A few respondents agreed generally with the proposed changes set out in the consultation paper, typically saying it is a fairer system, more empathetic, and will positively impact equality. A few respondents made general comments on the need for equality for all carers as well as access to all services. One individual suggested that those with protected characteristics should have less stringent requirements regarding eligibility for the benefit.

A small number of respondents foresaw the need for all unpaid carers to receive the same level of support.

Some respondents focused on groups of people who share protected characteristics, and these remarks are summarised in the following paragraphs. However, it should be noted that some respondents referenced multiple protected characteristics, for example, women who are disabled or women who are from an ethnic minority group.

Women

A few respondents remarked on women who are carers, agreeing with the consultation paper which noted that caring roles fall most typically to women, with caring more likely to have a negative impact on greater numbers of women than men. A campaigning / advocacy organisation commented that single parents are predominantly women, more likely to be reliant on social security benefits and experience poverty. There were also references to disabled migrant women, and women from south Asian communities who may be caring for multiple family members but who do not consider themselves to be carers and might not apply for the support to which they are entitled. It was also felt that language barriers might prevent some women for whom English is not always their first language from applying for support.

Age

Of the small number of respondents who mentioned age, most focused on the elderly in that caring can be more difficult for them. Again, there were a very small number of comments that pensioners should be entitled to Scottish Carer's Assistance. A very small number of respondents focused on young carers, with one request for children under 16 who are carers to be eligible for Scottish Carer's Assistance.

Disability

A few respondents discussed disabled people, with comments that there can be overlapping issues which impact on those with disabilities. One individual pointed out that disabled people are disadvantaged if they receive ESA

(Employment and Support Allowance) as they then lose their Carer's Allowance. Another individual felt that care experienced young people are not assessed for disabilities quickly enough and that this should in itself be an additional protected characteristic. One respondent perceived that individuals with health conditions such as epilepsy may need more support and financial help and may rely more on carers. Additionally, some of these are carers themselves and there is likely to be a negative financial impact on all carers when diagnosed with epilepsy.

Race

A few respondents remarked on individuals within ethnic minority groups. The key issue was that this group of people need to be encouraged to apply for the support to which they are entitled, as many will be either unaware of their entitlement or will not want to come forward to ask for help. Furthermore, information needs to be provided in various language formats, as not all individuals will speak fluent English.

Sexual orientation

A very small number of remarks related to sexual orientation. A campaigning / advocacy organisation noted that there can be issues for LGBT+ individuals in receiving support for a caring role if they do not want to declare the nature of their relationship to the cared for individual.

Other references

Other remarks were made regarding individuals living on the islands or in rural communities where it might be difficult to access help and services. There were also a few references to the need for more support for working carers or those who would like to work, with requests for the earnings threshold to be eased.

A few respondents – primarily organisations – foresaw a need for the Scottish Government to work alongside representative carer groups and those with lived experience in the development of these proposals, with one noting the need for engagement with communities using a Human Rights based approach. Concerns over eligibility criteria and carers with no recourse to public funds were raised by a small number of organisations, with a suggestion that more data is needed to ascertain the number of carers across Scotland.

One organisation advocated the need to differentiate carers who look after individuals with profound and multiple learning disabilities (PMLD) or with complex needs and their reality of caring, from that of families caring for a child with less complex needs.

Island Communities Impact Assessment

The consultation paper outlined a number of issues which impact on island communities. It also noted that Social Security Scotland's Local Delivery function will provide support to applicants in rural areas, which will be an improvement on the support offered through the current system. The Scottish Government will also be putting in place a monitoring and evaluation plan for Scottish Carer's Assistance prior to implementation that is intended to take account of the issues identified with the completed Island Communities Impact Assessment.

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

Only 32 respondents provided commentary at this question, although some others stated they could not comment, as they do not live in an island community.

Most of the information provided by respondents echoed the issues outlined in the consultation paper. The two most cited issues by significant numbers of these respondents were the limited services available and the costs of accessing these services. In terms of the former, respondents noted a lack of health professionals, amenities and services in island communities, with fewer opportunities for carers to access the necessary services. Examples given included a lack of local providers, reduced availability of services, and a lack of day care and respite provision. As such, a third sector carer's organisation noted that caring roles on the islands can be more intensive due to a lack of social care provision. A couple of respondents also noted that there may be increased feelings of isolation for carers in island communities, and an individual commented that a loss of interaction and support can lead to a decline in mental health for carers.

Linked to the latter issue, respondents noted that it costs more to access services and that the cost of living is higher for island communities (one representative body / association commented that the cost of living is estimated to be 15-30% higher). Fuel poverty rates are also higher on the islands. Overall, it was felt that island communities are more economically disadvantaged than their mainland counterparts. As one local authority commented:

"Residents in island communities, such as Highland, experience different complexities, costs of living, access to services, and lifestyles when compared with those living in an inner city. Many families in rural areas will run a car at the expense of other essential requirements to access further and higher education, employment, and essential services. In addition, food and fuel are often more expensive for island communities and those living in rural areas. Issues such as increased travel costs to access employment and services, low pay which is often linked to seasonal employment and the historical low take up of benefits all compound the issues of financial hardships and poverty. These factors mean residents in the Highlands and other rural areas in Scotland have different experiences when compared with inner cities. Thus, service design needs to accommodate these different needs in order to achieve the best possible outcomes."

Digital exclusion and unreliable broadband services were cited by a few respondents as being an issue for island communities, although two third sector organisations also noted that direct face-to-face communication can be a challenge due to geographical distance. A campaigning / advocacy organisation noted:

"We have, through dialogue with our rural and island-based customers, learned about the extra challenges they face such as paying higher costs for their energy usage (due to a lack of energy options available), poor infrastructure and transport options, and poor connectivity and broadband coverage which hinders their ability to seek out support online."

A very small number of respondents noted that it can be difficult to find part-time employment on the islands and thus obtaining additional finance for a household is more challenging.

Ways of overcoming these specific challenges were mentioned by a small number of organisations. These included suggestions for tax credits to be offered to carers in these locations to reflect the different environment in which they deliver care; to offer a rural supplement to Scottish Carer's

Assistance to help address the additional costs of fuel, food and transport; and to offer free travel to those living in island communities.

While this question focused on island communities specifically, a small number of respondents also noted that these issues are not specific solely to island communities, but that mainland rural and remote communities suffer from the same issues and challenges such as limited services and access to these.

Fairer Scotland Duty

The Scottish Government is also keen to look at how Scottish Carer's Assistance can help to reduce the challenges that people can face as a result of socio-economic disadvantage, which can include having a low income, not having access to basic goods and services, or having a background which gives them fewer advantages. In developing detailed policy for Scottish Carer's Assistance, the Scottish Government will be looking further at how it could do more to help tackle the disadvantages people face because of financial and economic inequality.

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.

A total of 62 respondents answered this question, many points mirroring those raised in the consultation paper. The key theme to emerge, and cited by respondents across most sub-groups, was support for the proposals in the consultation paper. It was perceived that these will help to reduce socioeconomic disadvantage, with many of the proposals positively impacting on people living in poverty.

Issues where respondents agreed with points raised in the consultation paper included agreement that women are disproportionately affected by caring and that providing care can result in significant personal and economic costs. One third sector organisation noted that it is vital that the gendered impact of providing unpaid care is addressed. Linked to this, there were also a few comments that individuals with socio-economic disadvantage are least able to advocate for themselves, that the current cost of living crisis has exacerbated socio-economic disadvantage, and that many carers are significantly restricted in their ability to be socially and economically active and have limited life opportunities due to their caring role.

Other themes which have been cited in earlier questions included:

• The need for carers to be given recognition and support in their role.
• All carers should be able to have an equal quality of life with non-carers.
• Requests for changes to eligibility criteria: this included requests to raise the earnings threshold as this currently does not allow for stable or sustainable career options for carers; changes to the requirement for a minimum of 35 hours per week caring commitment; and revisions to the rules which tie the provision of the benefit to the cared for person's disability benefit entitlement.
• Requests for the introduction of a Minimum Income Guarantee.
• Receipt of Scottish Carer's Allowance should entitle carers to additional services that help to reduce disadvantage, such as free travel on public transport, regular health checks, and assistance in finding skilled employment.
• Provision of support services such as community hubs, which can provide information on other services, and benefits to which carers might be entitled; or education and information for carers who are disadvantaged.

A few respondents noted their agreement with these proposals but felt that they need to go further. A representative body noted that there is a need for significant changes to reduce poverty levels, and an organisation in the health sector felt that there is a need for longer term changes to relieve financial pressures (including the current cost of living crisis, the earnings cap and the inadequacy of other social security benefits).

Very small numbers of organisations noted the need to tackle the root causes of poverty, and a couple of individuals felt that socio-economic disadvantage should be prioritised over other groups with protected characteristics.

Child Rights and Wellbeing Impact Assessment

The consultation paper noted that a Child Rights and Wellbeing Impact Assessment will be carried out for Scottish Carer's Assistance to help to ensure that this will protect and promote the wellbeing of children and young people. Scottish Carer's Assistance will be available to carers aged 16 and over so the consultation noted that it is expected the primary impacts will be on young people aged 16 and over.

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.

A total of 53 respondents answered this question, some of whom noted the importance of children's rights and wellbeing as a consideration and felt the proposals would have a positive impact on children and their rights, improve financial stability and increase recognition of child carers. Linked to this, a few individuals saw a need to protect children and to ensure they are at the centre of any decision-making. There were a number of general remarks that the proposals in this consultation paper will lead to improvements for young carers in terms of maintaining social connections through education, supporting their wellbeing and having a positive impact on mental health.

Other views, each advocated by very small numbers of respondents included:

• Young carers are currently not recognised but should be and should get more financial assistance and more support in the future.
• All young carers need to be made aware of their entitlement to benefits.
• Changes to Scottish Carer's Assistance that remove barriers for accessing full-time education will mean more carers will be able to study and improve their life chances. Young carers will be less likely to have to make a choice between education and caring.
• The Scottish Government should work with young carer's organisations.
• There should be a consistent age definition for children across all policy areas.

Business and Regulatory Impact Assessment

The consultation paper noted that 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. The Scottish Government has considered the potential business and third sector impacts of introducing

Scottish Carer's Assistance, including Carer's Additional Person Payment. Question 48 asked:

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

Only 30 respondents provided comments at this question, with a few noting their agreement that the impact on businesses needs to be considered.

A key view espoused by a few respondents was the need for all businesses to have a basic understanding about the caring role and the impact this can have on an individual, for example, being limited in the number of hours that can be worked. A representative body noted that businesses need to be flexible and creative in their contractual arrangements, and that the need for changes to working practices during the pandemic has shown this is possible. Allied to this, a few respondents also noted that the consultation proposals might benefit businesses as carer employees may be able to work longer hours, with resulting benefits for the business and the carer's mental health. The proposals may also help to ease recruitment and retention problems currently being experienced by some businesses. A representative body / association noted:

"The increase in the earnings limit for carers and the increase in hours that carers are able to work could benefit employers. There have been workforce shortages, with recruitment and retention of staff remaining challenging in the public, third sector and independent sector. While not all carers will be able to work, it will depend on their individual circumstances, but those who can may help ease the workforce challenges across the sectors while improving their financial situation. The pandemic has taught that standard work patterns can change; hybrid working and working from home are attractive options and offer flexible arrangements that may suit some carers. The impact on business in each of the sectors will require them to become flexible and creative in their contractual arrangements with staff."

A very small number of respondents, mostly organisations, suggested that there would be economic benefits from these proposals. A third sector organisation noted that carers could be more socially and economically active in their communities, and a local authority perceived that increased benefits would mean more spend in local businesses.

The need for advice and support activities was highlighted by a very small number of respondents. A health organisation suggested that guidance should be provided to businesses about the employment of carers, and an individual noted that carer organisations can advise businesses on how to support carers within their workforce. There were a small number of references to removing the earnings threshold and / or revising the number of hours a carer can work before their benefits are impacted.

Additional comments

A few respondents provided additional comments, some of which reiterated points made at earlier questions.

Some of these respondents welcomed the opportunity to respond to the consultation and provided background information on their organisation to provide context for their response.

The issues raised included:

• There is a need to improve support for carers. This includes welfare benefits and other means of assistance such as respite breaks.
• Support for carers needs to be easier to access with Social Security Scotland staff based in carer centres to provide advice and support to carers. Reference was made to obtaining tailored peer support and mental health provision. At a consultation event, respondents noted that Social Security Scotland's staff need to be able to understand the process from a carer's perspective and to understand different disability conditions.
• Scottish Carer's Assistance should be extended to include a wider range of carers including people of pension age and full and part-time students.
• Scottish Carer's Assistance should be based on the Scottish Living Wage.
• Scottish Carer's Assistance should be provided on a sliding scale so that those in greater need can receive a higher benefit level, for example, islanders and those in rural Scotland where higher numbers of people suffer from fuel poverty.
• The names and range of different payments is confusing to carers.
• There is a need for support for carers to enable them to fulfil their caring role as well as enabling external support to be brought in where necessary, as some carers have to manage their own condition as well as look after the cared for person.
• Payments to long-term carers should be based on existing information rather than via an intrusive application process.