EQIA: Policy 20 - ILF Scotland Payments

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: Equality Impact Assessment (EQIA) for Policy 20 - ILF Scotland Payments
Name of person completing EQIA: Jill Fotheringham
Date EQIA completed: 30 July 2026

What type of activity are you planning?

Change to Policy: Yes
Change to Procedure: No
Change to Service: No
Change to Office Plan / Budget: No
Project: No
Event: No

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

The policy revisions introduce payment arrangements for Coming Home Recipients, including the removal of the maximum payment limit from 3 August 2026. The revisions also clarify circumstances where ILF Scotland can exceed maximum awards and make payments to support independent living outcomes. The changes are intended to support people with learning disabilities and complex support needs to move from inappropriate settings, avoid delayed discharge from hospital and maintain independent living.

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

Coming Home Recipients, their families and carers, Health and Social Care Partnerships (HSCPs), and ILF Scotland staff

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: No
Comments: No differential impact identified.

Disability: Yes
Comments: Positive impact for disabled people who meet the Access Principles for the Coming Home Fund. Removal of the maximum payment limit may reduce barriers to independent living, support discharge from hospital, prevent inappropriate placements and help maintain community-based support arrangements.

Gender Reassignment: No
Comments: No differential impact identified.

Marriage and Civil Partnership: No
Comments: No differential impact identified.

Pregnancy and Maternity: No
Comments: No differential impact identified.

Race: No
Comments: No differential impact identified.

Religion or belief: No
Comments: No differential impact identified.

Sex: No
Comments: No differential impact identified.

Sexual orientation: No
Comments: No differential impact identified.

Is there evidence of any impact on other groups not covered by the protected characteristics? If yes use the Comments column to describe what the potential impact is, what you could do to remove/reduce any negative impact and what you could do to benefit from any positive impact.

(For example, carer status, single parent, economic exclusion. It is important not to limit your thinking just to the protected characteristics listed above. This question is broadening the EQIA out to be more inclusive. The impact might be a negative one (e.g. making that decision could decrease the opportunity for some people to participate) or it could be a positive one (e.g. by making that decision, more people are able to take part in the activity).)

Positive potential impact on unpaid carers, families and people with care experience. Increased flexibility in funding may help maintain community-based support arrangements, reduce reliance on institutional care and support people to live independently in their local communities. The changes may also benefit people living in rural and remote areas where more flexible support arrangements are required.

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).

If there are gaps in information that make it difficult to form an opinion on how your policy, service or change might affect different groups of people, gather other information to help you make an informed decision 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.

Policy revisions were informed by engagement through engagement events for disabled people and their families and for professionals, Scottish Government and other statutory partners involved in Health and Social Care, the ILF Scotland Advisory Group, the ILF Re‑Opening Co‑Production Group, which includes representatives from Disabled People’s Organisations (DPOs) and other third sector partners.

The Coming Home policy amendments have been developed with input from:

• Scottish Government
• Health and Social Care Partnerships
• disabled people and families
• ILF Scotland staff and Advisory Groups
• Members of the Coming Home Action Plan Short Life Working Group

Two engagement events with the public were held on 25 May 2026 and 26 May 2026.

Information about these events was widely shared across our social media platforms, on our website, with Disability People’s Organisations.

Details contained in the Coming Home Action Plan 2026 - gov.scot.

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: No
Disability: No
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.

No adverse impacts noted.

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: No

Disability: Yes

Gender Reassignment: No

Marriage and Civil Partnership: No

Pregnancy and Maternity: No

Race: No

Religion or belief: No

Sex: No

Sexual orientation: No

The policy changes may have a positive impact on disabled people by removing financial barriers to independent living and allowing funding arrangements to better reflect individual need. The removal of the maximum payment limit for Coming Home Recipients add to existing public financial resources and may help prevent delayed discharge from hospital, reduce inappropriate placements and support sustainable community living.

The changes may have a positive impact on people with care experience by supporting transitions from institutional settings and reducing the risk of prolonged or inappropriate placements.

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?

The policy revisions for Coming Home promote equality of opportunity by:

• supporting disabled people to live independently
• reducing institutionalisation
• increasing choice, control and flexibility
• aligning with Article 19 of the UN Convention on the Rights of Persons with Disabilities

The policy changes may have a positive impact by reducing barriers to independent living for disabled people with high support needs.

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

Policy revisions and the practical impact on will be monitored and reviewed the ILF Coming Home team delivery. We will continue to consult with Re‑opening Co‑production Group, Scottish Government and statutory partners. We will seek feedback from Coming Home recipients and their representatives.

This plan is signed off by: Linda Scott
Title: Director of Policy, Improvement & Engagement
Date: 3 August 2026