EQIA: Policy 24 - Statutory Input to ILF Scotland Funding

In completing this EQIA, you should be ensuring that you give thought to the needs of diverse groups of people 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 whom the change may impact.

Name of Activity: Equality Impact Assessment (EQIA) for Policy 24 - Statutory Input to ILF Scotland Funding
Name of person completing EQIA: Linda Scott, Director, Policy, Improvement and Engagement
Date EQIA completed: 27 January 2025

What type of activity are you planning?

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

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

Applicants to the Independent Living Fund are required to meet a number of access principles, including, from 1 April 2024 being in receipt of a social care support package / SDS of at least £800 per week. This is referred to as the Threshold Sum.

This is a policy change to the access principles of the fund to include an element of unpaid care in the way of a notional Care Component that can be added to the applicant’s net SDS budget, up to the value of £315 per week, to bring the budget up to the £800 Threshold Sum.

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

The change to policy could affect applicants to the Independent Living Fund who are applying after 27 January 2025 and who have an unpaid carer living in the same house who provides a significant level of unpaid care, to the extent that they would meet the Threshold Sum if this care was provided on a paid basis.

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: We know that unpaid care is very often provided to our recipients by their elderly parents and the role can be significant for people who may develop their own health issues as they get older. This policy change will provide additional funding to allow disabled people to better meet the independent living outcomes that are important to them while providing an opportunity where needed for the unpaid carer to step back a little from a caring role and enjoy more of a family role.

Disability: Yes
Comments: Stakeholders told ILF Scotland about the extent of care that was provided on an unpaid basis and the Co-production Working Group recognised that potential inequity existed in the operation of a threshold sum model of access to the re-opened fund, where the focus is only on funded support. This meant that disabled people who have significant support needs that are met through unpaid care were at a disadvantage in accessing the ILF. This change to policy will allow people with an unpaid carer who lives with them and who provides a significant amount of care and who would be eligible for an Adult Carer Support Plan to now apply to the Fund.

Gender Reassignment: No
Comments:

Marriage and Civil Partnership: No
Comments:

Pregnancy and Maternity: No
Comments:

Race: No
Comments:

Sex: Yes
Comments: The vast majority of unpaid carers are women so this policy change helps to address the disproportionate expectations placed by social pressures on women, which can impact on their ability to secure paid employment or enjoy retirement / social lives / personal wellbeing.

Sexual Orientation: No
Comments:

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 to just the protected characteristics listed above. The 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).)

Yes – the change to policy should allow those with unpaid care greater access to ILF Funding, which in turn could be beneficial to unpaid carers.

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).

The Co-Production Working Group, having identified a need to review the Threshold Sum in relation to unpaid care, set up a sub-group to progress this matter. The Group has representation from Scottish Government, ILF Scotland, local authorities and Disabled People’s Organisations and therefore was able to consider a range of feedback and analysis.

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
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.

The proposals affect applicants to the Independent Living Fund as of 27 January 2025 and no adverse impact has been determined.

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 - as outlined above
Disability: Yes - as outlined above
Gender Reassignment: No
Marriage and Civil Partnership: No
Pregnancy and Maternity: No
Race: No
Religion or Belief: 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?

The change to Policy has been communicated to Local Authorities and to the ILF Scotland website and through our Scotland and Northern Ireland Advisory Groups.

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 will continue by ILF Scotland and the Co-Production Group.