Young Carer Grant regulations: consultation analysis

Impact Assessments

As part of the consultation document, the Scottish Government included summaries of various impact assessments that had been conducted to date. These included:

• A summary of the Equality Impact Assessment (EQIA);
• A summary of the Children's Rights and Wellbeing Impact Assessment (CRWIA); and
• A summary of the Business and Regulatory Impact Assessment (BRIA).

Respondents were invited to identify and describe any additional potential impacts related to each of these assessments that had not already been identified. This chapter outlines the responses given in relation to each impact assessment.

Equality Impact Assessment (EQIA)

An Equality Impact Assessment involves assessing the impact of new or revised policies, practices or services against the requirements of the public sector equality duty. The duty requires all Scottish public authorities to have due regard to the need to eliminate unlawful discrimination, advance equality of opportunity and foster good relations. It covers people in respect of all aspects of equality, and helps to ensure the needs of people are taken into account during the development and implementation of a new policy or service or when a change is made to a current policy or service.

The consultation document set out data and evidence related to age, disability, race, sex, and sexual orientation. It also highlighted evidence gaps in relation to gender reassignment, marriage and civil partnership, pregnancy and maternity, and religion and belief. Overall, it was considered that the Young Carer Grant would not directly or indirectly discriminate on the basis of any protected characteristic but, rather, the policy would apply equally to those affected by its provisions and was expected to bring positive impacts to all equally. Respondents were asked if they were aware of any potential equality impacts that had not already been identified in the document.

Q8. Are you aware of any equality impacts on age, disability, gender reassignment, marriage or civil partnership, pregnancy or maternity, race, religion or belief, sex or sexual orientation of the Young Carer Grant that we have not identified?

	Number	Percentage
Yes	15	20%
No	60	80%
Total	75	100%

Most respondents (80%) indicated that they had identified no further equality impacts, while one in five (20%) offered suggestions for impacts which had been overlooked.

Of those that indicated they could identify additional potential equality impacts, the main concerns focused on the age range and educational requirements for eligibility. As discussed above, many respondents felt the age range was too narrow and should be expanded to include those aged 18 regardless of their educational or work status, with one respondent suggesting the upper age limit should be extended to age 20. Others felt that restricting eligibility to only those enrolled in school was discriminatory towards those who have chosen other means of education, such as home education, college or university:

"In the eligibility, only 18 year old that are still in school get the grant. I think that no matter what you're doing, you should still be able to get the grant." (Individual)

"It is unfortunate that young carers aged 18 and attending uni or college are not entitled to apply." (Organisation)

One organisation also highlighted a link between the age/educational limits and potential gender impacts. They indicated that female carers aged 16 to 24 were less likely to enter education compared to male carers, and suggested that the Young Carer Grant could provide an opportunity to support young female carers to access education if it was made available to all:

"In making the grant available to all young carers, no matter their educational status, the grant could positively impact this and ensure more young female carers have the opportunity to enter education." (Organisation)

The accessibility of the grant and application form was also discussed by some respondents. In particular, three respondents noted that the application form needed to be suitably tailored for transgender applicants, allowing them to use names, pronouns and gender that they identified with (rather than those assigned at birth). One other felt that alternative formats of the application paperwork needed to be made available (e.g. BSL and simplified versions) to ensure the process was accessible to all. Meanwhile, two respondents discussed the need for awareness raising and promotional campaigns which are suitably tailored to ensure maximum support for applicants, and uptake of the grant by young carers from equality groups, including young carers from the travelling community.

Other issues identified by one respondent each included:

• A potential stigma for those who care for people who have HIV/AIDS and/or mental health issues; and
• That the regulations assume that young carers have the capacity to apply and have no additional needs themselves, which will not always be the case. It was felt there was a need to identify who could support individuals that do not have capacity or understanding and have not identified themselves to a service.

Children's Rights and Wellbeing Impact Assessment (CRWIA)

The Scottish Government wants to make Scotland the best place in the world for a child to grow up, and recognising, respecting and promoting the rights of children and young people is considered essential to achieving this. Ongoing steps are being taken by the Scottish Government to ensure that children experience their rights, as determined by the United Nations Convention on the Rights of the Child (UNCRC). In drafting the regulations, a Children's Rights and Wellbeing Impact Assessment was carried out to help ensure that the policies, measures and legislation proposed protect and promote the wellbeing of children and young people.

The summary of the Children's Rights and Wellbeing Impact Assessment included within the consultation document outlined the relevant data, and addressed how the Young Carer Grant policy may impact upon the relevant articles of the UNCRC and on the relevant Getting It Right For Every Child (GIRFEC) wellbeing indicators. The CRWIA concludes that the Young Carer Grant policy will not infringe upon the rights of the child as set out in the articles of the UNCRC, or the indicators of wellbeing as set out by the Children and Young People (Scotland) Act 2014. Rather, any impact of the policy should be neutral or positive.

Respondents were again asked to indicate any additional impacts which the Young Carer Grant may have on the children's rights and wellbeing which were not already considered by the CRWIA.

Q9. Are you aware of any impacts of the Young Carer Grant on children's rights and wellbeing that we have not identified?

	Number	Percentage
Yes	6	8%
No	67	89%
No response	2	3%
Total	75	100%

Again, most respondents were unable to identify any additional impacts.

Of those that did identify additional possible impacts, four respondents stressed the importance of ensuring the Young Carer Grant allows young carers to make autonomous choices regarding their caring role and that it does not inadvertently lead to some young people continuing in unsuitable caring roles:

"A grant like this can be seen as encouragement for a young carer to stay in their caring role rather than seek support to limit [their] caring role. Especially with the criteria being 16 hours and above a week. A young carer may decide to just continue caring because they are being paid to do so." (Organisation)

There were suggestions among these respondents that additional support should be given to young carers to ensure that their caring role is age-appropriate, to access additional support for the person they care for and themselves where appropriate (i.e. to alleviate their caring role), and to help them decide on their own future goals and ensure that their caring role is not a barrier to them pursuing these.

Two of these respondents also felt there was a need to support young carers in managing their finances, for example, by assisting them to set up a bank account and/or supporting them in deciding what they wish to use the grant for. Again, it was felt that, for some young carers, there may be the potential for parents/ guardians to pressurise them into spending the grant on things other than themselves, therefore such support and/or future follow up to measure the impact of the grant may be sensible.

Three respondents again suggested that the grant be made available to all young carers aged 16-18, regardless of their educational/employment status. One stressed that the £300 payment was a small amount of money compared to the caring responsibilities that young carers undertake, and that it was unfair for young carers to not be eligible for Carer's Allowance if they are also in full time education.

There was also a call from one organisation for the Scottish Government to clarify whether being in receipt of the Young Carer Grant will have any impact on entitlement to other support, for example, the Education Maintenance Allowance.

Another organisation indicated that the issue of hidden carers had been well documented, along with the barriers that exist for young carers accessing support and information services, and the stigma related to addictions and mental health. All of these could be relevant in relation to the Young Carer Grant, it was felt.

Business and Regulatory Impact Assessment (BRIA)

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 consultation document indicated that the Scottish Government expects that the Young Carer Grant will help in the promotion of the Economic Strategy and in the delivery of the priorities for sustainable growth. It states that the Young Carer Grant represents an additional Scottish Government spend of approximately £500,000 each year into the Scottish economy and, therefore, positive impacts upon businesses were expected. The consultation document provided a summary of the Scottish Government's Business and Regulatory Impact Assessment and invited respondents to identify any additional potential impacts not already included.

Q10. Can you identify any business related impacts of the Young Carer Grant that we have not identified?

	Number	Percentage
Yes	4	5%
No	69	92%
No response	2	3%
Total	75	100%

Only four respondents indicated that they were able to identify additional business related impacts, while most respondents indicated that they could not, or did not answer the question.

Of these four, one organisation felt that further quality assurance was needed and that they could not know the impact on businesses because there was no way to know what young carers would spend the money on. Another organisation questioned how the Young Carer Grant would sit alongside Education Maintenance Allowance (EMA) payments. Meanwhile, one individual suggested that the money could be used to help young carers to start/set-up their own businesses.

The fourth respondent (an organisation) who indicated that they could identify additional impacts suggested that, while the estimated spend of £500,000 into the economy would be good for business, the payments were too low and did not reflect the true cost of having to deliver equivalent replacement care (which they estimated would total £26 million). As such, they felt that the grant did not reflect the main principles of the Carers Act:

"In that context, £500,000 could be considered as meeting the policy aims of the grant, but contradicting the underpinning principles of the Carers Act. This could be viewed as Scottish Government policy condoning children propping up health and social care services." (Organisation)

One organisation, who did not provide a response to the closed question, did provide a qualitative response. While they did not identify any new or additional impacts, they outlined agreement with the Scottish Government's Business and Regulatory Impact Assessment that the introduction of Social Security Scotland could cause additional requests for information and support from existing advice services. They outlined a number of reasons for this, including:

• That the introduction of a new system in Scotland (alongside the UK system) has the potential to increase complexity for claimants;
• Changes to benefits make clients concerned, as recent changes have involved reassessments and/or reductions in payments;
• Two substantial benefit changes (i.e. Universal Credit and Personal Independence Payment) are still being rolled out to many claimants in Scotland. Demand for advice on these issues will inevitably increase at the same time as the new Scottish system is embedded;
• Tens of thousands of claimants are likely to be worse off as a result of the UC and PIP roll out, they perceived; and
• The move to digital public services will cause access problems to those who lack online access and skills.

They suggested that the confusion created by both a new system/benefit along with changes to, and the introduction of other benefits at the same time, would lead to uncertainty for claimants and introduce challenges for advice services to provide accurate information. However, they also saw opportunities to improve the system that would help to support their work and potentially reduce the need for advice over the long-term:

"More confusion and help needed, with separate systems running in parallel. Clients now do not always know what benefits they are receiving so the new powers will add complexity… They will be anxious about losing their benefits or having to claim again under a new system. They will also be worried that they will be paid less or there will be a delay in payment... If the proposed changes are made it is likely benefit enquiries would increase in the short term but ideally long term we'd see more people out of poverty and potentially lower demand on services." (Organisation)