EQIA: Policy 14 - Qualifying Benefits for ILF Scotland Awards

In completing this EQIA you should be ensuring the needs of diverse groups of people are thought about when developing and implementing a new policy, procedure or service or a change to existing ones. Please consider the protected groups in line with the Equality Act 2010 and other diverse groups who may be impacted.

Name of Activity: Policy 14 Qualifying Benefits for ILF Scotland Awards
(previously entitled Policy 14 DLA / PIP / ADP Appeals)
Name of person completing EQIA: Linda Scott
Date EQIA completed: 05/10/2022

What type of activity are you planning?

Change to procedure: No
Event: : No
New procedure: No
Office Plan/Budget: No
Policy: Yes
Project: No
Service: No
Other (free text box): No

1 Describe the main aim or purpose of what it is you are planning to do?

Review of policy. Wording revision.

2 Who is likely to be affected by this policy, service or change?

All 2015 fund recipients.

3 Do you have enough information to know what the potential impact might be on diverse groups and what that might look like?

The protected characteristics to consider are: Age, Disability, Sex, Race, Religion or Belief, Gender Reassignment, Sexual Orientation, Marriage and Civil Partnership, Pregnancy and Maternity. It will also be helpful to consider these groups more widely in relation to their socio-economic status that includes such factors as educational attainment, occupation, income, wealth and social deprivation.
Please mark as Yes or No. If yes use the Comments column to describe what the potential impact is. What are your sources of evidence?

(Try to think about both positive and negative impacts. There are lots of sources of data to help answer this question. Diversity Networks, the Diversity Report or Diversity & Inclusion team may offer some useful information. Previously completed EQIAs may also offer answers to questions you may have).

Age: Yes
Comments: Recipients are an aging population and we are aware that many of their informal carers are also older people. We recognise the Social Security Agency Appeals Process can be a source of additional stress, and as older people, Recipients and their Award Managers are more likely to experience the negative effects of stress. Evidence also suggests there are high rates of successful decision appeals in respect of disability / health related benefits.
Sources: 'It's Broken Her' - Assessments for disability benefits and mental health (Rethink Mental Illness)
Personal Independence Payment: Official Statistics to January 2022 (UK Department of Work and Pensions)
Optimising Older Peoples Quality of Life: an Outcomes Framework (NHS Health Scotland)
Struggling with stress? (NHS inform)

Disability: Yes
All recipients are identified as having a substantial disability / impairment. We recognise the Social Security Agency Appeals Process can be a source of additional stress, and as disabled people, Recipients and their Award Managers are more likely to experience the negative effects of stress. Evidence also suggests there are high rates of successful decision appeals in respect of disability / health related benefits.

Sources: DWP admits wrongly refusing PIP to record number of Disabled people (Disability Rights UK)
Personal Independence Payment: Official Statistics to January 2022 (UK Department of Work and Pensions)
'It's Broken Her' - Assessments for disability benefits and mental health (Rethink Mental Illness)
Disability and stress: A study in perspectives (Journal of Intellectual & Developmental Disability/ researchgate.net)

Gender reassignment: No
Marriage and Civil Partnership: No
Pregnancy and Maternity: No
Race: No
Religion or belief: No
Sex: No
Sexual orientation: No

Carers: Yes
Comments: Award Managers are often informal carers for the recipient, and can also experience high levels of stress in their daily lives. Any change to a Recipient’s eligibility for ILF could have an indirect impact on informal carers by increasing their caring role.
Sources: Chapter 2: Carers' Health and Wellbeing - Scotland's Carers - (Scottish Government)

4 Have you consulted with the relevant groups (these could be internal and/or external) or gathered evidence for you to know the potential impact on these different groups affected? What sources have you used to gather information?

If there are any gaps in information that make it difficult or impossible to form an opinion on how your policy, service or change might affect different groups of people, please take the time to gather information to help you make an informed answer (for example, review statistics, survey results, complaints analysis, consultation documents, customer feedback, existing briefings submissions or business reports, comparative policies from external sources and other Government Departments etc).

Desk research, consultation with ILFS Assessors, Specialist Caseworkers, Recipients, Award Managers, Scottish Advisory Group, NI Stakeholder Group.

5 Having analysed the relevant sources of information, what does the evidence tell you? Is there any evidence that the proposed changes will have an adverse equality impact on any of these different groups of people?

Age: Yes
Comments: As above

Disability: Yes
Comments: As above

Gender Reassignment: No
Marriage and Civil Partnership: No
Pregnancy and Maternity: No
Race: No
Religion or belief: No
Sex: No
Sexual orientation: No

6 Please provide details of who the proposals affect, the adverse impacts and explain how you will minimise or remove the adverse impact.

Recipients have been identified as those primarily affected by this policy as a direct result of any decision to reduce or withdraw their DLA, PIP, CAA, AA, ADP or AFIP by the relevant authorities. In recognition of the stress associated with any change to benefit entitlement, the high rate of overturned decisions to reduce or withdraw benefits, and the impact of the potential loss of ILF eligibility, we have incorporated the benefit appeal timeframe into our policy to ensure that ILF payments remain in place until the appeal process has been completed. This will permit some additional time for recipients to liaise with social services or other sources of support in respect of their care or assistance needs should they no longer be eligible to receive ILF. The policy is available on the ILFS website and available in alternative formats upon request.

7 Is there any evidence that the proposed changes will have a positive impact on any of these different groups of people and/or promote equality of opportunity? Please provide details of which group/ groups benefits from the positive impacts. and how this will be promoted/evaluated.

Age: Yes
Comments: By having a policy for benefit appeals, Recipients and Award Managers are made aware of what impact any loss of specified benefits will have on their eligibility to receive ILF. Additionally, the policy outlines what to expect if they are in the process of appealing a benefit entitlement decision.

Disability: Yes
Comments: By having a policy for benefit appeals, Recipients and Award Managers are made aware of what impact any loss of specified benefits will have on their eligibility to receive ILF. Additionally, the policy outlines what to expect if they are in the process of appealing a benefit entitlement decision.

Gender Reassignment: No
Marriage and Civil Partnership: No
Pregnancy and Maternity: No
Race: No
Religion or belief: No
Sex: No
Sexual orientation: No

8 Provide a final summary of the commitments/actions you will take as a result of completing this EQIA. Who will you consult with on your action plan and how will you do this to ensure the relevant stakeholders understand the equality impact?

We will continue to inform Recipients / Award Managers of this policy via our website, and contact with our Assessors and Specialist Caseworkers, Scottish Advisory Group and NI Stakeholder Group.

9 Have you a plan in place to review your actions? Please provide a summary. Will plan require sign off and from where.

Ongoing monitoring and review of policy impact on Recipients and their Award Manager via feedback from Assessors and Specialist Caseworkers, Management Team, and Senior Management Team. Policy will be signed off by Linda Scott, Director of Policy, Improvement and Engagement.