The Social Security (Residence Requirements) (Ukraine) (Scotland) Regulations 2022: scrutiny report
The Scottish Commission on Social Security's scrutiny report on the Social Security (Residence Requirements) (Ukraine) (Scotland) Regulations 2022
- Document Cover
- Summary of Recommendations and Observations
- 1. Introduction
- 2. Delivery, partners and co-ordination
- 3. Raising awareness
- 4. Monitoring: challenges and implications
- 5. Opening up access and advancing equality and non-discrimination
- 6. Take up
- Annex 1 – Overview of support schemes
- Annex 2 – Approach to Scrutiny
Summary of Recommendations and Observations
Recommendation 1: In view of the delivery challenges across the public sector generated by significantly greater than expected take-up of the super-sponsor scheme, the Scottish Government and Social Security Scotland should place particular importance on planning for and monitoring of whether expectations in ‘Our Charter’ continue to be fulfilled.
Recommendation 2: While it may be hard to disentangle the specific impact of these draft Regulations from the provision of different kinds of support to displaced people previously resident in Ukraine, there is therefore a case for reviewing this, where possible identifying the impact on different partners and learning from experience, in preparation for any similar future occurrence, to ensure all partners have capacity to deliver.
Recommendation 3: Social Security Scotland is invited to set out how it intends to monitor its ability to get information to displaced people on devolved benefits so that they can get access them quickly.
Recommendation 4: Social Security Scotland is invited to share details of action taken to ensure displaced people previously resident in Ukraine are made aware of relevant Charter expectations and how to raise concerns if Charter expectations are not being met.
Recommendation 5: In view of difficulties in identifying exact numbers of displaced people previously resident in Ukraine accessing devolved social security, and noting exact numbers may not be required, Social Security Scotland should nonetheless consider the implications for learning directly from specific communities on their experiences of accessing support and put in place systems that can support continuous improvement directed towards these communities.
Observation 1: While time may well not permit the drawing up of impact assessments in advance of the laying of regulations of this kind, there may be a case for doing so retrospectively, as a means of drawing on learning as a preparatory measure should similar regulations be required in future.
Recommendation 6: The Scottish Government undertakes an equality analysis of the impact of these Regulations.
Recommendation 7: Social Security Scotland is invited to set out details of action taken to ensure accessibility of information to people arriving under these schemes who have additional disability-related communication barriers.
Observation 2: Independent, accessible and rapidly available advocacy on devolved social security may well be of particular importance to displaced people previously resident in Ukraine coming to Scotland.
Recommendation 8: Scottish Government carries out active, ongoing engagement with displaced people previously resident in Ukraine, not just in order to improve their awareness of devolved benefits, Charter expectations and advocacy support available but to monitor, evaluate and apply learning to future communications, take-up and delivery strategies.