The Carer Assistance (Carer Support Payment) Amendment Regulations 2024: scrutiny report

The Scottish Commission on Social Security's scrutiny report on the draft Carer Assistance (Carer Support Payment) Amendment Regulations 2024

Impact assessments

The draft policy note highlighted that a review of the existing impact assessments, undertaken ahead of the principal regulations, indicated that there were no significant equalities or rights impacts that require further consideration. However, officials have indicated to SCoSS that, as part of reviewing impact assessments for the purpose of these regulations, decisions such as phasing by authority area and backdating were to mitigate potential risks of differential treatment identified by reviewing the impact assessments of the original regulations. We understand that a summary of these considerations will be included in an updated policy note.

In addition, the Scottish Government indicated that, due to data limitations, it had considered age and gender information in its impact assessment and found that while “the proportions of carers by age group and gender in each phase were similar to the proportion of carers by age group and gender across Scotland overall” people over State Pension age “are marginally more likely to be living in the final phase”. As those over State Pension age are less likely to be affected by the changes being made to full-time education and ‘past presence’ rules, however, that this would not have any significant impact.

SCoSS welcomes these clarifications but notes the continuing lack of information around CSP claimants. The approach to data collection about CSP clients in future should allow for improved insights into the protected characteristics of these groups to allow for a stronger consideration of equality matters in planning future changes to CSP and carer support.

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