Carer’s Allowance Supplement (Scotland) Bill - Equality Impact Assessment (EQIA)
In deciding to progress a further Coronavirus Carer’s Allowance Supplement, the Scottish Government has considered its aim to support carers to protect their health and wellbeing, so they can continue to care if they so wish, and have a life alongside caring. The Bill contains necessary measures required to support unpaid carers by providing extra financial support and puts in place an enabling provision that would allow for a more flexible approach to future payments should this be required. The Scottish Government is satisfied that all of the measures contained in the Bill are appropriate and proportionate.
The Bill aims to provide unpaid carers who receive Carer’s Allowance with extra financial support in recognition of the extra burden the pandemic has placed on carers and due to the loss of income and increased costs many have faced as a result of the coronavirus outbreak. It is intended that this will help to mitigate negative financial impacts and help to relieve some of the stress associated with additional and different caring responsibilities. This is in line with the Scottish Government’s broader policy objective to support carers to protect their health and wellbeing, so they can continue to care if they so wish, and have a life alongside caring.
This extra support will be will be paid as an increased amount of Carer’s Allowance Supplement for the period from 1 October 2021 to 31 March 2022. As the extra support for this period is intended to help address the effects of the coronavirus outbreak, the amount by which the Carer’s Allowance Supplement is increased is referred to in this document as the ‘Coronavirus Carer’s Allowance Supplement’.
The Bill also proposes to confer a delegated power on the Scottish Ministers to enable the Scottish Ministers to introduce regulations to provide unpaid carers who receive Carer’s Allowance with extra financial support if necessary.
Carer’s Allowance Supplement (£231.40 in 2021-22) is a payment made twice annually to those persons who, on the qualifying date for each supplement, were in receipt of Carer’s Allowance and resident in Scotland, (or otherwise met the eligibility conditions referred to in section 81(2A) of the Social Security (Scotland) Act 2018 (“the 2018 Act”)).
To be eligible for Carer’s Allowance an individual must be 16 or over, spend at least 35 hours a week caring for a person who qualifies for specified disability benefits, meet the residence requirements, not be in full-time education or studying for 21 hours a week or more, not be subject to immigration control, and not earn more than £128 per week after tax, National Insurance and expenses.
Coronavirus Carer’s Allowance Supplement is intended to have a positive impact on the approximately 83,000 carers in Scotland who are in receipt of Carer’s Allowance, and an indirect positive impact on the people they care for.
The Scottish Government has considered the potential impacts of Coronavirus Carer’s Allowance Supplement on people with one or more protected characteristics by revisiting the 2018 Equality Impact Assessment for Carer's Allowance Supplement. Through this process aspects of Coronavirus Carer’s Allowance Supplement have been identified which would positively impact on carers who fall in to one or more of the protected groups, or to people in these groups who are cared for. In summary, it is anticipated that Coronavirus Carer’s Allowance Supplement will have a direct positive impact on women (because the majority of carers are women), and indirectly on the disabled children and adults they care for by reducing stress on carers and contributing to household finances.
There is insufficient evidence available on gender reassignment, pregnancy and maternity, and religion and belief to assess the payment’s impact on these groups. Limited data is available on sexual orientation and carers. Research from Carers Trust Scotland and LGBT Youth Scotland highlights that LGBT young carers face barriers in having both their LGBT and carer identities recognised by support services.
The scope of the EQIA
The scope of this EQIA is the impact of Coronavirus Carer’s Allowance Supplement on unpaid carers, and the people they care for, who have one or more protected characteristics. Eligibility for Carer's Allowance Supplement is based on receipt of Carer’s Allowance, however changes to Carer’s Allowance are not within scope of this EQIA.
A variety of information sources were used in compiling this EQIA, including:
- DWP Stat-Xplore
- Scotland’s Carers 2015
- Scottish Health Survey 2012/13
- Scottish Health and Care Experience Survey 2013/14
- Scotland’s Census 2011.
This EQIA should be read in conjunction with the other impact assessments conducted for the Carer’s Allowance Supplement (Scotland) Bill as a whole, namely:
- the Business and Regulatory Impact Assessment (BRIA)
- Child Rights and Wellbeing Impact Assessment (CRWIA)
- Data Protection Impact Assessment (DPIA)
- Strategic Environmental Assessment (SEA)
- Fairer Scotland Duty (FSD)
- Islands Communities Impact Assessment (ICIA).
The Scottish Health Survey and Scotland’s Census provide robust survey data, although it can be difficult to identify people who are carers. Research with carers has shown reasons for this include:
- People providing care may not identify themselves as a carer, rather than as a relative or friend to the person they care for.
- Caring can start at a low level and often include ‘invisible tasks’ such as monitoring and emotional support which are less recognised than more tangible tasks.
- Carers may be more likely to identify as carers as the role becomes more intense.
- For an individual to accept their role as a carer, they need to acknowledge that the person they are supporting needs care – which can be difficult for one or both parties to do.
The Scottish Government does not anticipate that the Coronavirus Carer’s Allowance Supplement will have a significant impact on people due to their age. Some age related statistics have been included below:
- As of August 2020, there are 83,000 carers in receipt of Carer’s Allowance. This includes around 500 carers under 18, and around 3,200 carers over the age of 65.
- A further almost 38,700 carers in Scotland have an underlying entitlement to Carer’s Allowance but do not receive it. 85% of the carers with underlying entitlement (around 32,800) are over State Pension Age. The most likely reason for this group not to be in payment of Carer’s Allowance is that they are in receipt of the State Pension, so are not able to receive a payment for Carer’s Allowance due to overlapping benefit rules. The remaining 15% are likely to be in receipt of another earnings-replacement benefit, such as Jobseeker’s Allowance or Employment Support Allowance, and are therefore ineligible under the same overlapping benefit rules.
- Analysis published in 2015 estimated there were around 29,000 young carers in Scotland aged 4-15.
- The Scottish Health Survey (2018) showed the prevalence of unpaid care varies significantly by age, increasing from 4% among those aged 4-15 to 8% among those aged 16-24 to 23% among those aged 45-54 followed by a decrease to 12% of those aged 75 and over.It also showed a higher proportion of carers aged 65 and over reported providing 50 hours or more of unpaid care each week (22%) than younger age groups (14% of those aged 45-64, 12% of those aged 16-44 and 2% of those aged 4-15).
- Many young people who provide support and help to family members who need it often do not recognise this as a ‘caring’ role. Australian and UK studies have suggested that this is especially common among some minority cultural and ethnic communities.
- Research from Citizens Advice Scotland found 38% of people aged 65 to 79 who accessed their services were unable to use a computer, compared to just 3% of people aged 18 to 24. 46% of those aged between 65 and 79 reported they never used the internet compared to just 1% of those aged 18 to 24.
- Information on the age of people cared for by those in receipt of Carer’s Allowance is not publically available.
The Scottish Government has not been able to draw any conclusions from these statistics that would suggest the Coronavirus Carer's Allowance Supplement will have a significantly disproportionate impact on people due to their age.
Young carers under 16 will not benefit directly from the further Coronavirus Carer’s Allowance Supplement payment, as it is necessary to be 16 or over to apply for Carer’s Allowance which is an income replacement benefit. However, the Scottish Government anticipates that the Bill will have indirect positive impacts on children and young people who are cared for by someone in receipt of Carer’s Allowance and who receive extra financial support under the Bill through increased household income.
The Scottish Government anticipates that the Coronavirus Carer’s Allowance Supplement payment in December 2021 will likely have a positive impact on women, as the majority of Carer’s Allowance recipients (69 per cent) are female.
StatXplore information from August 2020 shows that Women are more likely to be in receipt of or meeting the entitling conditions of Carer’s Allowance, over 75% of those entitled to Carer’s Allowance are women in the 30-34 age group, after this age the proportion of women caring falls very gradually to around 64% in the 60-64 group, with women making up 56% of over 65s. The vast majority or Coronavirus Carer’s Allowance Supplement recipients would be women of working age, as most carers or pension age and above will have only underlying entitlement to Carer’s Allowance (because the State Pension is an ‘overlapping benefit’) and means that Carer’s Allowance, and so Coronavirus Carer’s Allowance Supplement, will not be paid.
Evidence shows that women are more likely to rely on social security payments as
part of their incomes as men, and there is some evidence that women typically act
as ‘poverty managers’, going without food and other vital resources so that other family members do not.
- Women working full time were significantly more likely than men working full time to provide unpaid, regular care (17% of women, compared with 12% of men).
- Women are more likely than men to view caring tasks as integral to their existing role and responsibilities rather than as separate "caring”.
According to Women’s Budget Group briefing, women have been disproportionately impacted by cuts to disability benefits, both as claimants and as carers.
Women are most likely to be in receipt of disability and ill health benefits. 55% of adults in receipt of the disability benefits Attendance Allowance, Disability Living Allowance at the middle or high care component or Personal Independence Payment with a standard or enhanced care component are women. Additionally women are more likely to provide unpaid care. The 2011 census and Scotland’s carers’ publication reported that around 59% of unpaid carers are women.
There is some initial evidence to show women may be disproportionately affected by the economic impact of the pandemic due to lower incomes and increased caring responsibilities. 
The Scottish Government also anticipates that Coronavirus Carer’s Allowance Supplement would have a positive impact on disabled people, as the person the carer looks after will be in receipt of disability benefits. The payment can help maintain the health and well-being of the carer, which has consequential positive impacts for the person who is cared for, and in cases where the carer lives with the cared for person, a potentially positive impact on overall household finances.
Figures on the number of disabled people receiving Carer’s Allowance are not publicly available, though benefit combination information suggests that in August around 13,600 working age carers meeting eligibility for Carer’s Allowance were also in receipt of Disability Living Allowance or Personal Independence Payment. A further 15,000 state pension age carers meet the entitling conditions for Carer’s Allowance and are in receipt of one of Personal Independence Payment, Disability Living Allowance or Attendance Allowance. Among the broader group of unpaid carers caring for 35 hours or more per week, 50% of unpaid carers reported they had one or more long term conditions. The Scottish Health Survey 2018 found that mental wellbeing is lower among those who spend a greater number of hours per week providing unpaid care.
Carer’s Allowance eligibility is reliant on the person the carer looks after being ‘severely disabled’ – defined as being in receipt of a specified disability benefit, either Attendance Allowance, the highest or middle rate of Disability Living Allowance care component, either rate of the daily living component of Personal Independence Payment, Armed Forces Independence Payment, Constant Attendance Allowance at or above the normal maximum rate with an Industrial Injuries Disablement Benefit, or Constant Attendance Allowance at the basic (full day) rate with a War Disablement Pension.
Information on recipients of Carer’s Allowance by race is not publicly available and therefore impact on race cannot be assessed fully, however the Scottish Government does not anticipate that the Coronavirus Carer’s Allowance Supplement will have a significant impact based on race.
Census data gathered in 2011 suggests that around 9 per cent of people in Scotland provided unpaid care and this varies across ethnic groups. People from older ethnic groups such as 'White: Scottish' and 'White: Other British' were the most likely to provide unpaid care.
People from ethnic groups with younger age profiles (such as the 'Arab' and 'White: Polish' groups) were least likely to provide weekly unpaid care. People from the White: Gypsy/Traveller group were most likely to be providing unpaid care and to be providing 35 hours or more of unpaid care (the threshold for Carer’s Allowance). The next most likely to provide 35 hours or more of unpaid care were Bangladeshi and Pakistani groups.
No data is available on pregnancy and maternity in recipients of Carer’s Allowance. Maternity Allowance is an overlapping benefit with Carer’s Allowance. Carers receiving Maternity Allowance in full will not be able to receive Carer’s Allowance or the supplement. Full Maternity Allowance is paid at a higher rate than Carer’s Allowance with the supplement. Those receiving partial Maternity Allowance may receive partial Carer’s Allowance and would then receive the supplement in full.
Impact of Coronavirus Carer’s Allowance Supplement on those in protected groups
The Scottish Government has assessed the potential impact of the proposed measure on equal opportunities and no negative impacts have been identified in relation to any of the protected characteristics of age, disability, sex, pregnancy and maternity, gender reassignment, sexual orientation, race, religion or belief, marriage or civil partnership, either directly or indirectly. The Scottish Government anticipates that a Coronavirus Carer’s Allowance Supplement payment in December 2021 will likely have a positive impact on women, as the majority of Carer’s Allowance recipients (69%) are women.
The Scottish Government also anticipates that the measure will have a positive impact on disabled people, as the person the carer looks after will be in receipt of a qualifying disability benefit. The payment can help maintain the health and wellbeing of the carer, which has consequential positive impacts for the person who is cared for, and in cases where the carer lives with the cared for person, a potentially positive impact on overall household finances.
Recommendations and conclusion
The Scottish Government has concluded that no changes to the Bill provisions are necessary as a result of the EQIA.
Monitoring and review
The Social Security (Scotland) Act 2018 places a duty on the Scottish Ministers to publish an annual report on the performance of the Scottish social security system. On-going engagement with key stakeholders, including carer organisations, will also provide the Scottish Government with an opportunity to monitor the impact of the policy. Audit Scotland monitor and report on the delivery of the social security system, including Social Security Scotland.