Integrated Impact Assessments – Contributing to your care – social care charging policies
Contributing to your care – social care charging policies
- The overall ‘style’ of the documents has been changed to make them easier read and more accessible for members of the public.
- Any content which will change on an annual basis (for example, the actual charges, capital limits, personal allowances) has been removed from the policy documents. Similarly, the worked examples have also been removed from the policies themselves. Links are included in the policy documents to this information to ensure it remains accessible.
- The introduction of ‘interim charging’ for residential services. This in effect means that people will be charged at a rate equal to the minimum contribution they will be required to make whilst a financial assessment is being carried out. Once the assessment has been completed the contribution will be adjusted. The process to implement this will ensure that the level of any interim contribution will always be less than or equal to the final contribution.
- A waiving of charges for anyone admitted to a care home for specialist palliative care. The older people’s pathways programme commissioned by the Edinburgh Integration Joint Board (IJB) has recognised that the city needs a pathway that incorporates end-of-life care in a care home. Accordingly, officers are working on an end-of-life care home service specification, and a procurement from willing independent homes that will cover parts of the city where the Council has no suitable home. The associated finances are covered in the direction issued by the Integration Joint Board to the Council and NHS Lothian on date. This change will bring the residential policy in line with the non-residential one.
No public involvement is planned.
25 July 2024
| Name | Job Title | Date of IIA training |
| Sarah Hayden | SE Locality Business Manager (facilitator 25 July) | |
| Rachael Docking | Programme Manager – Innovation and Sustainability Team, EHSCP (facilitator 01 August) | Feb 2020 |
| Moira Pringle | Chief Finance Officer [Lead Officer], EHSCP | |
| Katie McWilliam | Strategic Planning and Quality Manager, EHSCP | |
| Alan Wilson | Senior Social Worker, EHSCP | |
| Andrea Ritchie | Transactions Team Manager, Corporate Services – City of Edinburgh Council | |
| Fiona Johnston | Senior Accountant, Corporate Services – City of Edinburgh Council | |
| Hugo Whitaker | Development Worker, EVOC | |
| Iain McGregor | TBC | |
| Jill Acheson | Senior Social Worker, EHSCP | |
| Kimberley Swan | ||
| Neil Jamieson | Head of Customer Services, Corporate Services – City of Edinburgh Council | |
| Sheila Haig | Customer Manager, Transactions, Corporate Services – City of Edinburgh Council | |
| Pauline Walker | Project Implementation Manager, EHSCP | |
| Matt Kennedy | Head of Assessment and Case Management, EHSCP | |
| Sophie Milner
(report writer) |
Project Manager – Innovation and Sustainability Team, EHSCP | February 2020 |
| Emma Gunter | Contracts Manager, EHSCP | Joined second IIA meeting |
| Evidence | Available – detail source | Comments: what does the evidence tell you with regard to different groups who may be affected and to the environmental impacts of your proposal | |||||||||||||||||||||||||||
| Data on populations in need | National Records of Scotland (NRS) population projections
Population and demographics – Edinburgh Health & Social Care Partnership (edinburghhsc.scot) EIJB Strategic Plan 2019 – 2022 Edinburgh Joint Strategic Needs Assessment (JSNA) Audit Scotland Report on Health and Social Care Integration Scottish Commission for People with Learning Disabilities |
Edinburgh’s population is expected to increase from 527,620 (mid-2020) to 575,576 by 2037.
The average age of the population of City of Edinburgh is projected to increase as the baby boomer generation ages and more people are expected to live longer. Estimates of future numbers of older people are sourced from National Records of Scotland (NRS) population projections for local authority areas. The number of people aged 85+ living in Edinburgh is projected to increase by 80% between 2018 and 2043. Edinburgh will also see an increase of those with complex and long-term care needs within the adult population, driving a growing need for specialist resources and an impact on future adult service provision. Edinburgh is estimated to have 30,735 adults aged 16-64 with moderate to severe disabilities. In Edinburgh it is estimated that there are 2,255 people (5.0 people per 1,000) with a learning disability (known to the local authority – this varies by authority but includes those receiving advocacy from partner agencies, Further Education, employment support, in addition to directly provided social care). Of the 2,255 people with a learning disability in Edinburgh, 1,970 are aged 18-64 and 285 are 65+. There are estimated to be 65,084 carers in Edinburgh, or 13.7% of the population. One in five of these carers provides over 50 hours of care a week. Adult social care services face considerable challenges in order to address identified current and future demographic pressures. |
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| Data on service uptake/access | Data, Performance and Business Planning Team, The City of Edinburgh Council. | The figures below were submitted to Learning Disability Statistics Scotland last year from EHSCP. The figures represent the people who are involved with the Learning Disability teams within the Partnership but not necessarily the number of people with a learning disability or known to us as having a learning disability.
The figures below represent the purchased services for people with learning disabilities in Edinburgh through the EHSCP. There could be some people receiving more than one service so cannot be used to show overall use.
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| Data on socio-economic disadvantage e.g. low income, low wealth, material deprivation, area deprivation. | SIMD (Scottish Index of Multiple Deprivation)
Population and demographics – Edinburgh Health & Social Care Partnership (edinburghhsc.scot) Edinburgh Poverty Commission Christie Commission (2011) |
The Scottish Index of Multiple Deprivation (SIMD) provides a relative measure of deprivation across Scotland. It provides key data on socio-economic disadvantage. Edinburgh consists of 17 wards and 597 data zones:
· The mean population of the datazones in Edinburgh is 860 (ranging from 258 [an area in Oxgangs] to 3,847 [including the Riccarton campus of Heriot-Watt University] and a median of 836) · By ranking all datazones in Scotland from most deprived to least deprived it is possible to see what proportion of the population in Edinburgh live in the 20% most deprived areas of the country, as well as the other quintiles to the 20% least deprived · People living in the most deprived areas are statistically more likely to experience health inequalities. This means lower life expectancy, higher rates of disease, more long-term illness · People living in the least deprived areas have a life expectancy 8 years (males) and 4.8 years (females) higher than those in the most deprived areas · Areas in Edinburgh with greatest disadvantage The Christie Commission highlighted that the greatest challenge facing public services is to combat the negative outcomes for individuals and communities arising from deep-rooted inequalities. Vocal survey highlights 72% of respondents finances were impacted as a result of their caring role with 65% having stopped working completely or reducing their working hours in order to provide unpaid care. The proportion of carers not in employment, education, or receiving a pension has reduced from 34% in 2021 to 18% in 2023. Overall, the Vocal survey highlights more carers in Edinburgh are experiencing ill health, poorer personal finances and employment circumstances, and greater difficulty in accessing support services. While these have been factors for carers for a long time, they have been exacerbated during the double blow of COVID-19 – and the resultant closure or suspension of services – and the current challenging economic circumstances, which have placed greater financial pressures on caring households Statistics show that people with learning disabilities do not yet enjoy the same life chances as others |
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| Data on equality outcomes | JSNA-Health-Needs-of-Minority-Ethnic-Communities-Edinburgh-April-2018.pdf (edinburghhsc.scot)
EHSCP Edinburgh ‘Offer’ Pact Consultation 2019 Strategic-Plan-2019-2022-1.pdf (edinburghhsc.scot) scotland.shinyapps.io/sg-equality-evidence-finder/ Scottish Women’s Budget Group (swbg.org.uk) The Carers Strategy – Edinburgh Health & Social Care Partnership (edinburghhsc.scot) |
JSNA Provides data on demographics of minority ethnic communities
Edinburgh Offer Pact Consultation raised themes for the citizens of Edinburgh around: · Making information accessible · Equality /SIMD; · Aware of those who do not have a voice; · Fairness; · Meaningful consultation (allowing time to respond) EHSCP IIA Strategic Plan 2019-22: There is considerable data available on health inequalities showing significant inequalities throughout all parts of Edinburgh as well as inequalities for some nongeographic groups. Women and men use public services differently, and there is a great variety of experiences between women – we have different life experiences and face different economic realities and challenges. Women are often disadvantaged by policies that do not recognise these different experiences. The strategy sets out strategic priorities of planning partners to act as gateways for carers, not as gatekeepers. To this end, it commits to strengthening our partnerships city-wide and in our communities, building on the progress made through the implementation plan of Edinburgh Joint Carer Strategy 2019-2022 |
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| Research/literature evidence | National health and wellbeing outcomes framework – gov.scot (www.gov.scot)
Adult Social Care: independent review – gov.scot (www.gov.scot) The Carers Strategy – Edinburgh Health & Social Care Partnership (edinburghhsc.scot) |
The evidence tells us that people want person-centred care that is flexible and responds to people’s changing needs.
The Carers Strategy sets out strategic priorities of planning partners to act as gateways for carers, not as gatekeepers. To this end, it commits to strengthening our partnerships city-wide and in our communities, building on the progress made through the implementation plan of Edinburgh Joint Carer Strategy 2019-2022 4. |
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| Public/patient/client experience information | EHSCP Satisfaction Consultation Feedback March 2021
Home care survey |
EHSCP Satisfaction Consultation Feedback early findings indicate areas of support individuals and carers value the most for the care and support they receive through external care providers
Satisfaction with home care services – 2022 Number of people resident in our CEC Care Homes – · Castlegreen – 38 (4 SF) · Clovenstone – 22 (4 SF) · Ferrylee – 26 · Fords Road – 34 (3 SF) · Inch View – 54 (5 SF) · Jewel House – 33 (SF 2) · Marionville Court – 50 (SF 3) · North Merchiston – 36 (SF 6) · Royston Court – 52 (SF 2) Further information can be found: |
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| Evidence of inclusive engagement of people who use the service and involvement findings | Independent Review of Adult Social Care (2021)
Edinburgh-Carer-Survey-2023-Report.pdf (vocal.org.uk) There are a number of resources that highlight these services to the public and front line staff – Worrying about money, the council website – cost of living, Money Counts training, Connect Here – Food, Money and Finance. |
Views of carers within Edinburgh and Midlothian. The challenges facing carers have increased since 2017, with increasing impacts on health and finances. The age profile of carers is also shifting to increasingly include younger carers, as challenges continue to increase more support will be required.
Edinburgh-Carer-Survey-2023-Report.pdf (vocal.org.uk) Work is currently underway with colleagues in procurement to develop a new framework agreement for the provision of support for adults who have learning disabilities. A specification has been produced, informed by engagement with service users. Feedback from service users indicated a preference for more flexibility in support with evening and weekend opportunities and also some focus on support to explore employment and volunteering possibilities. Income max services i.e. welfare rights and debt advice – there are many service providers, however there are 4 main ones: The Advice Shop, CHAI, Citizens Advice Edinburgh (CAE) and Granton Information Centre (GIC) and specialist services like VOCAL (for carers) and The Action Group, LCIL, FAIR Ltd for disabilities. Edinburgh as a whole supports 20,000 people with welfare rights and debt advice annually, which results in an annual financial gain of £20m. Citizens Advice Edinburgh (CAE) presentation from August 2023 focused on debt and highlighted 90% of their clients in Edinburgh seeking debt advice declare that they are disabled. See slides 8 and 12 of the presentation attached. In response to this, the City of Edinburgh Council and EHSCP Public Health Practitioners are working with CAE and FAIR on a proposal using Scottish Government Child Poverty Accelerator Funding. The proposal involves tests of change to understand how to prevent this debt and update Easy Read resources and what other mitigating factors could be applied. |
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| Evidence of unmet need | Independent Review of Adult Social Care (IRASC)
Data, Performance and Business Planning Team, The City of Edinburgh Council. Public Health Scotland Data |
IRASC: As the older population has increased and resources have been focused increasingly on those in greatest need, a smaller proportion of the adult population is in receipt of social care support than before austerity, with the result that the needs of a number of people are probably not being met and for others they are being met in a crisis response rather than to anticipate or avoid such interventions.
The waiting list for people with a learning disability to be assessed is 113 in total. There are 14 people with a learning disability waiting (759.25 hours) for a package of care. Public Health Scotland – demand for care at home services across Scotland |
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| Good practice guidelines | COSLA-Social-Care-Charging-Guidance-2022-23.pdf | The guidance provides a framework for Councils to adopt whilst allowing for local accountability and discretion. It encourages Councils to adopt best practice in the development of their policies.
CRAG – Charging for residential accommodation guidance |
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| Carbon emissions generated/reduced data | N/A | ||||||||||||||||||||||||||||
| Environmental data | N/A | ||||||||||||||||||||||||||||
| Risk from cumulative impacts | N/A | ||||||||||||||||||||||||||||
| Other (please specify) | N/A | ||||||||||||||||||||||||||||
| Additional evidence required | N/A | The outstanding invoices are shown below, broken down by category. There are a small number of people who have more than one invoice so the data cannot be used as an overall figure.
Accommodation charge – 373 South East Learning Disabilities – 20 South East Physical Disabilities – 14 South East Mental Health – 66 South East Older People – 22 South West Mental Health – 73 South West Physical Disabilities – 13 South West Older People – 30 South West Learning Disabilities – 21 North East Mental Health – 105 North East Older People – 28 North East Physical Disabilities – 27 North East Learning Disabilities – 43 North West Mental Health – 48 North West Physical Disabilities – 15 North West Learning Disabilities – 17 North West Older People – 31 Intensive Housing Management – 3 Community Living – 9 Supporting People (Alarms) – 2485 |
| Equality, Health and Wellbeing and Human Rights
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Affected populations |
| Positive
Policy format
If we are more consistent in our approach to charging this is a positive impact The updated policies ensure that the correct charges are allocated for services. Provide people and their families guidance on how contributions will be calculated and charges applied. Without clear policies, supported by strong operational procedures, on contributions to the cost of social care services there is a risk of inconsistent treatment of people who require care. The proposed policies have been co-produced with relevant stakeholders and are aligned with all relevant legislation and guidance.
Embedding links to relevant websites rather than having specific figures would limit the frequency the policy would need to be reviewed The current draft is easier to read, follow, and understand Interim charging changes (residential services)
Greater transparency and clarity surrounding charging. It aims to avoids situation where people are presented with large bills that they didn’t know about or had not prepared for them – there is a charge, albeit a minimum charge initially
No one should be charged anything that is not affordable and based on their income – the financial assessment should mitigate some negative impacts
Empowering for the worker knowing exactly what you are going in to say when working with people
Fits in with wider policies e.g. debt recovering policy – bringing it in-line with wider payments
Palliative care element
Ensure the correct communication to care homes when this is put in place. DS1500 – form is completed to confirm they are terminally ill or palliative care – there needs to be something to confirm they are at end of life before could waive charges
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Staff.
All adults accessing services, including older adults, people of middle years, young adults, adults with physical or learning disabilities, long-term conditions, mental health issues or sensory loss. Young people and children. Carers and Young carers. Care experienced children and young people. People vulnerable to falling into poverty. All families. Particularly older people and people with a disability All (as above) EHSCP organisation All – especially those with LD or complex needs All adults accessing services, including older adults, people of middle years, young adults, adults with physical or learning disabilities, long-term conditions, mental health issues or sensory loss. Young people and children. Carers and Young carers. Care experienced children and young people. People vulnerable to falling into poverty. All families. Particularly older people and people with a disability EHSCP frontline staff EHSCP organisation EHSCP organisation Someone receiving palliative care, their family EHSCP |
| Negative
All changes more likely to impact older people and people with disabilities, where the greatest volume of policy use will be
Policy format
The policy document shared for the Integrated Impact Assessment is lengthy. An EasyRead version that refers to the full policy would be more accessible. Action added to section 13.
There is a lack of clarity about section 8 and how people are charged. The day care charging is not clear – if people get day care they are not charged, if people get care at home in lieu of day care, they are charged – it reads like we charge for those items in b and c, but they are mechanisms for how to deliver – essentially anything that is not personal care we charge for. This is added to actions in section 13.
People who cannot fully pay fees, some may be able to pay the minimum charge – wherever possible the temporary minimum charge is applied, and ensure people are aware that there is a bill Equality issue linked to above point – ensure all can fully understand what is and is not charged. Further action added to section 13.
Interim charging changes (residential services)
There could be confusion for some people – need to know if there is a minimum interim charge and need to be clear so we know what to charge, as well as the mechanics of how the policy is applied. It will require the set amount in the policy. The language needs to be precise. We would not want people to understand the interim charge is the only charge applied and be unaware when a larger charge is requested. There is a need to separate the language from interim funding. Action added to section 13. Biggest impact won’t come from the policy but how we apply it e.g. frontline workers to understand the assessments they are making, people who are not being charged currently that will be in the future – and will people with reviews being undertaken be subject to the new policy? Action regarding guidance added to section 13. If someone lacks capacity, and has no family, the money is frozen – how do we support those people and how do we support frontline workers to reassure them. Internally, we know about people’s situation so will know if/ when to send a bill but we will need an internal process on how to manage those situations – practitioner guides on how the policy works. Action added to section 13. Impact for individuals who do not have access to public funds
Financial guardianship – where we can’t get access to the money until that is finalised – how would they pay minimum charge? We need to understand mechanics of putting the policy in place. Added to action in section 13 relating to practitioner guidance.
Palliative care element The definition of someone receiving palliative care needs to be clearer. There needs to be clear criteria about who it applies to and whom it does not. Action added to section 13. There could be challenges around equality. We need to be clear why we are making the distinction of someone who is receiving palliative care and the rationale of someone being in the right place, at the right time for the right care. The DS1500 form would need to be in place for exemption and some people would qualify who do not have a form. There needs to clear guidance. Action added to section 13.
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Older people
People with disabilities Carers All adults accessing services, including older adults, people of middle years, young adults, adults with physical or learning disabilities, long-term conditions, mental health issues or sensory loss. Young people and children. Carers and Young carers. Care experienced children and young people. People vulnerable to falling into poverty. All families. Particularly older people and people with a disability EHSCP organisation and All adults accessing services, including older adults, people of middle years, young adults, adults with physical or learning disabilities, long-term conditions, mental health issues or sensory loss. Young people and children. Carers and Young carers. Care experienced children and young people. People vulnerable to falling into poverty. All families. Particularly older people and people with a disability Someone who lacks capacity Self-funders Financial guardianship Someone receiving palliative care, their family and EHSCP organisation EHSCP organisation and All adults accessing services, including older adults, people of middle years, young adults, adults with physical or learning disabilities, long-term conditions, mental health issues or sensory loss. Young people and children. Carers and Young carers. Care experienced children and young people. People vulnerable to falling into poverty. All families. Particularly older people and people with a disability |
| Environment and Sustainability including climate change emissions and impacts
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Affected populations |
| Positive
No impacts disclosed
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| Negative
No impacts disclosed
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| Economic
|
Affected populations |
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Positive
Policy format
Greater transparency and clarity surrounding charging. It aims to avoids situation where people are presented with large bills that they didn’t know about or had not prepared for them – there is a charge, albeit a minimum charge initially
Interim charging changes (residential services) No one should be charged anything that is not affordable and based on their income – the financial assessment should mitigate some negative impacts
Alongside recent changes in operational practice, introducing interim charging would improve the Council’s cash flow position.
Palliative care
Waiving charges for people on an end-of-life pathway
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All adults accessing services, including older adults, people of middle years, young adults, adults with physical or learning disabilities, long-term conditions, mental health issues or sensory loss. Young people and children. Carers and Young carers. Care experienced children and young people. People vulnerable to falling into poverty. All families. Particularly older people and people with a disability
EHSCP organisation
Someone receiving palliative care, their family
|
| Negative
Policy format The policy presented needs to be clear about definitions and mechanisms for delivery to ensure it is consistently and fairly applied.
Interim charging changes (residential services)
Despite mitigating factors regarding the affordability of the interim charging through the financial assessment, there could be groups negatively impacted
Palliative care
Perceptions of lack of equity if the definitions of palliative care and when to apply the policy are not clear.
|
All adults accessing services including older adults, people of middle years, young adults, adults with physical or learning disabilities, long-term conditions, mental health issues or sensory loss. Young people and children. Carers and Young carers. Care experienced children and young people. People vulnerable to falling into poverty. All families. Particularly older people and people with a disability
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On occasion parts of this policy may be carried out by agency members of staff. These are largely regulated roles that require professional registration, which will provide assurance that equality, human rights, children’s rights are being adhered to. They will also be required to complete an induction and onboarding as per any new member of staff.
All communications plans/ strategies will be compliant with;
- UK Government guidance on Accessible Communication formats (2021); and
- The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018.
Consideration will also be given to the use of different mediums and channels for sharing information.
| Specific actions (as a result of the IIA which may include financial implications, mitigating actions and risks of cumulative impacts) | Who will take them forward (name and job title | Deadline for progressing | Review date |
| Work on an EasyRead version of the policy which directs people to full detailed policy | EHSCP Comms Team / Kimberley Swan | Required by 1 September 2024 | |
| Clarify section 8 to be clear what is and is not chargeable | Moira Pringle | 1 Sept 2024 | |
| Confirm language – minimum initial charge / temporary minimum charge, to separate the language from interim funding | Moira Pringle | 1 Sept 2024 | |
| Practitioner guides on how the policy works
To include all different types of scenarios about how to apply the policy and mechanics about when someone lacks capacity, financial guardianship. |
Matt Kennedy to nominate | 1 Sept 2024 | |
| Clarify what we mean by palliative care and the requirement for a DS1500 form
Crystal clear wording and criteria to be included in guidance |
Lead to be confirmed | 1 Sept 2024 | |
| For anyone receiving a care assessment after the policy was implemented, the information would need to be clear they now need to contribute for care. For anyone receiving care who currently does not pay for their care, the charges would be backdated to the point a care assessment (review) was conducted, not the point the service use began.
Updated process / guidance as required |
Lead to be confirmed | 1 Sept 2024 | |
| Currently producing an FAQ relating to health and social care charging. This will include FAQ in relation to Charging for Care Home and Non-Residential Charging. This is being produced using real customer feedback.
Link with EHSCP website information. |
Transaction Team | TBC – not expected to be ready by 1st September.
Transactions Team to update. |
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| Explore producing BSL/Braille versions of the policy using the Council’s interpretation and translation service | EHSCP Comms Team | 1st Sept 2024 |
The expectation is any feedback received though EHSCP Comms Team or other channels would be directed to the Income Maximisation Project Team.