Equality Impact Assessment

Strategy or Policy Template

Summer 2009

Name of the strategy or policy

Capital Funding Adaptation Major Adaptations

File ref:		Issue No:
Date of Issue:	June 13	Review date:	Feb 2021

ContentsEquality Impact Assessment 1

Part 1 The Public Sector Equality Duty and Equality Impact     Assessments  (EIA) 2

Part 2 – Aims and implementation of the proposal, strategy or policy 5

The statutory duties of local authorities in connection with adaptations are laid out below: 6

Part 4 – Assessment of impact 8

Part 5 – Conclusions and recommendations for decision makers 17

Part 6 – Equality impact assessment action plan. 19

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Part 1         The Public Sector Equality Duty and Equality Impact                                       Assessments  (EIA)

1.1       The Council must have due regard to its Public Sector Equality Duty when making all decisions at member and officer level.   An EIA is the best method by which the Council can determine the impact of  a proposal on equalities, particularly for major decisions. However, the level of analysis should be proportionate to the relevance of the duty to the service or decision.

1.2       This is one of two forms that the County Council uses for Equality Impact Assessments, both of which are available on the intranet. This form is designed for any proposal, strategy or policy. The other form looks at services or projects.

1.3       The Public Sector Equality Duty (PSED)

The public sector duty is set out at Section 149 of the Equality Act 2010. It             requires the Council, when exercising its functions, to have “due regard‟to the need to

• eliminate direct and indirect discrimination, harassment and victimisation and other conduct prohibited under the Act,

• advance equality of opportunity and foster good relations between those who share a “protected characteristic‟ and those who do not share that protected characteristic (see below for “protected characteristics”

• foster good relations between persons who share a relevant protected characteristic and persons who do not share it

These are sometimes called equality aims.

1.4       A “protected characteristic‟ is defined in the Act as:

• age;
• disability;
• gender reassignment;
• pregnancy and maternity;
• race (including ethnic or national origins, colour or nationality)
• religion or belief;
• sex;
• sexual orientation.

Marriage and civil partnership are also a protected characteristic for the purposes of the duty to eliminate discrimination.

The previous public sector equalities duties only covered race, disability and gender.

1.5       East Sussex County Council also considers the following additional   groups/factors when carry out analysis:

• Carers – A carer spends a significant proportion of their life providing unpaid support to family or potentially friends. This could be caring for a relative, partner or friend who is ill, frail, disabled or has mental health or substance misuse problems. [Carers at the Heart of 21stCentury Families and Communities, 2008]
• Literacy/Numeracy Skills
• Part time workers
• Rurality

1.6       Advancing equality (the second of the equality aims) involves:

• Removing or minimising disadvantages suffered by people due to their protected characteristic

• Taking steps to meet the needs of people from protected groups where these are different from the needs of other people including steps to take account of disabled people’s disabilities

• Encouraging people from protected groups to participate in public life or in other activities where their participation in disproportionately low

NB Please note that, for disabled persons, the Council must have regard to the                     possible need for steps that amount to positive discrimination, to “level the                        playing field” with non-disabled persons, e.g. in accessing services through                     dedicated car parking spaces. 

1.6       Guidance on Compliance with The Public Sector Equality Duty (PSED) for officers and decision makers:

1.6.1   To comply with the duty, the Council must have “due regard” to the three equality aims set out above.  This means the PSED must be considered as a factor to consider alongside other relevant factors such as budgetary, economic and practical factors. 

1.6.2   What regard is “due” in any given case will depend on the circumstances.  A proposal which, if implemented, would have particularly negative or widespread effects on (say) women, or the elderly, or people of a particular ethnic group would require officers and members to give considerable regard to the equalities aims.  A proposal which had limited differential or discriminatory effect will probably require less  regard.

1.6.3   Some key points to note :

• The duty is regarded by the Courts as being very important.
• Officers and members must be aware of the duty and give it conscious consideration: e.g. by considering open-mindedly the EIA and its findings when making a decision. When members are taking a decision,this duty can’t be delegated by the members, e.g. to an officer.
• EIAs must be evidence based.
• There must be an assessment of the practical impact of decisions on equalities, measures to avoid or mitigate negative impact and their effectiveness.
• There must be compliance with the duty when proposals are being formulated by officers and by members in taking decisions: the Council can’t rely on an EIA produced after the decision is made.
• The duty is ongoing: EIA’s should be developed over time and there should be evidence of monitoring impact after the decision.
• The duty is not, however, to achieve the three equality aims but to consider them – the duty does not stop tough decisions sometimes being made.
• The decision maker may take into account other countervailing (i.e. opposing) factors that may objectively justify taking a decision which has negative impact on equalities (for instance, cost factors)

1.6.4   In addition to the Act, the Council is required to comply with any statutory Code of Practice issued by the Equality and Human Rights Commission. New Codes of Practice under the new Act have yet to be published. However, Codes of Practice issued under the previous legislation remain relevant and the Equality and Human Rights Commission has also published guidance on the new public sector equality duty.

Part 2 – Aims and implementation of the proposal, strategy or policy

2.1       What is being assessed?

a) Proposal or name of the strategy or policy.  What is being assessed–proposal, strategy or policy?

Adult Social Care (ASC) Capital Funding contribution towards Major Adaptations

b) What is the main purpose or aims of proposal, strategy or policy? Give a brief description of the main aims.

This proposal would adjust the existing policy on allocating Capital Funding for Major Adaptations to an individual home.  The aim is to ensure a fair and equitable allocation and commitment of the Capital Adaptations Budget for Major Adaptations, taking into account some of the additional difficulties experienced by disabled and older people with a physical/functional difficulty living in the community.

Historically there has been an under spend on the East Sussex Capital Programme allocation from the capital budget which is designated for topping up funding on those adaptations that exceed the £30,000 Disabled Facilities Grant (DFG) available funding.  There is an opportunity to look at if the budget could be used differently to mitigate some of the difficulties by assisting:

· Disabled individuals who need major adaptations to their property seem on paper to have sufficient funds to cover a loan for costs above £30,000 but in reality have heavy outgoing that will prevent them from taking out such a loan.

· Where individuals are assessed to contribute towards the cost of the adaptation following the grant final assessment who on paper seem to have sufficient income (assessed by the District and Borough using the national financial assessment for Disabled Facilities Grant) but in reality, have heavy outgoing and are unable to get a loan.  In these cases ESCC would pay the assessed contribution and require the individual to repay back the amount loan over time based on an amount they could afford. 

· Where the disabled person eligible needs exceed the scope for provision by the housing authority i.e. they fall outside the mandatory provisions for a DFG

c) Manager(s) and section or service responsible for completing the assessment. Explain why the members of the impact assessment team were selected, e.g. the knowledge and experience they bring to the process

            Michelle Crouch, Principal OT, ASCH

2.2       Who is affected by the proposal, strategy or policy? Who is it intended to benefit and how? Who are the main stakeholders in relation to this proposal, strategy or policy? Service users/carers/employees? What outcomes would other stakeholders want from this  proposal, strategy or policy?

Adults with a physical disability, sensory impairment and mental ill-health.

2.3       How is, or will, the proposal, strategy or policy be put into practice and who is, or will be, responsible for it? Who defines or defined the proposal, strategy or policy? Who implements the proposal, strategy or policy? How does the Council interface with other bodies in relation to the implementation of this proposal, strategy or policy? If external parties are involved, then what are the measures in place to ensure that they comply with the Council’s Equality Policy?

Currently the policy is operational within Adult Social Care.  Key practitioners responsible for the assessment of need eligible for funding from the capital budget are Occupational Therapy Staff.  The professional staff, following an assessment of need differentiate between what is desirable – what may be a perfectly legitimate aspiration on the part of the individual and what is actually needed for which support  from the public purse is justified.

When considering whether works are necessary and appropriate the assessment by the therapist must consider whether the proposed adaptation is needed in order for a care plan to be implemented and/or to enable the disabled occupant to remain in their own home, retaining or regaining a greater degree of independence. 

The proposed works would be expected to meet the assessed needs of the individual and take into account medical and physical needs as well as the needs owing to mental ill-health and any sensory impairement.  There may be also times when the psychological needs of both the disabled person and their carer will need specification consideration, particularly where the proposed works can assist in ensuring the ongoing care being given.

2.4       Are there any partners involved? E.g. NHS Trust, voluntary/community             organisations, the private sector? If yes, how are partners involved?

District and Borough Housing departments are responsible for the allocation of the Disabled Facilities Budget to which this capital funding relates. 

Also, these partners are responsible for funding the Adaptation Support Services that support individuals through the adaptation process.

2.5       Is this project or procedure affected by legislation, legislative change, service review or strategic planning activity?

The primary statutory duty in relation to this work are contained within the Care Act 2014.
Part 3 – Methodology, consultation, data and research used to determine impact on protected characteristics. To conduct the assessment, you will need information about service users and staff.  This section is to help you identify the sort of information that will be needed to help you assess whether there may be barriers to different equality groups who use your proposal, strategy or policy.

3.1List all examples of quantitative and qualitative data or any consultation information available that will enable the impact assessment to be undertaken.. Please note that both Census data and Staff Survey should be considered.  In some cases data may not exist or be available and you may therefore have to undertake additional research. If data is not available please state.

Types of evidence identified as relevant have X marked against them
	Employee Monitoring Data		Staff Surveys
	Service User Data		Contract/Supplier Monitoring Data
	Recent Local Consultations		Data from other agencies, e.g. Police, Health, Fire and Rescue Services, third sector
	Complaints		Risk Assessments
	Service User Surveys		Research Findings
x	Census Data		East Sussex Demographics
	Previous Equality Impact Assessments		National Reports
	Other organisations Equality Impact Assessments	x	Any other evidence? Strategic Housing Commissioners

3.2       Evidence of complaints against the strategy or policy on grounds of    discrimination. Is there any evidence of complaints either from service users or staff (grievance) as to the implementation of the proposal strategy or policy and its delivery on the protected characteristics?

None reported or collated by ASC Community Relations Team

3.3     If you carried out any consultation or research on the strategy or policy           explain what consultation has been carried out.

No consultation has been carried out

3.4       What does the consultation, research and/or data indicate about the positive or negative impact of the strategy or policy? Does any of the evidence show that there is a negative impact on one or more group of people? This will need to be ncluded/expanded on in Part 4.

a)

None undertaken

Part 4 – Assessment of impact

4.1       Age: Testing of disproportionate, negative, neutral or positive impact. Consider both issues affecting older and younger people.  An age group includes people of the same age and people of particular age ranges. An age group would include "over sixties" or twenty year olds.

a) How is this protected characteristic reflected in the County /District/Borough?

The overall population of East Sussex is 527,209 (2011Census data) and is projected to continue increasing over the next few years.   The population by age breakdown for East Sussex is:

Age                 Population

15-29              83,791

30-44              90,220

45-64              147,613

65+                 120,722

People are living longer and by 2020, it is estimated that around 38% of the UK population will be aged 50 plus and in East Sussex the figure is likely to be as high as 50%.

We know that East Sussex has a higher than average older population with around 23% of people aged over 65, compared to the national average of 16%. There are 228,881 people aged 50+ (43.4%) in East Sussex, and 20,022 (3.8%) of these are aged over 85 – East Sussex has one of the highest populations of people aged 85+ in the UK.  (2011 mid-year estimates, based on 2011 Census data).  The highest percentage of people over 65 years of age is in Rother, where the figure is 28.6% of the total East Sussex population.

b) How is this protected characteristic reflected in the population of those impacted by the proposal, strategy or policy?

This policy relates to adults with a physical disability including those of working age as well as older people.

c) Will people with the protected characteristic be more affected by the proposal, policy or strategy than those in the general population who do not share that protected characteristic? 

1. There is a potential for a positive impact on disabled people of a working age who on paper people seem to have sufficient income (assessed by District and Borough using the national financial assessment for Disabled Facilities Grant) but in reality have heavy outgoings that may mean they are unable to get loans to cover the element of the costs of work they would be responsible for.

The proposal is to waiver the necessity for individuals to apply for a loan themselves. ESCC would pay peoples assessed contribution upfront; and require weekly re-payments to recoup costs over time based on the amount they can afford to pay. 

This is a change since historically the Capital Budget has only been used to fund top-up funding for major adaptations (i.e. those over the £30,000 where the Disabled Facilities Grant does not cover the full cost of works).    You will need to refer to evidence gathered through monitoring and consultation in conjunction with the population statistics in a). Do you have any data available to show who will be affected by this proposal, policy or strategy? Or is this unknown due to there being no data available?

d) What is the proposals impact on different ages/age groups?

There will be an overall positive impact helping overcome the barriers to independent living and reduce risks posed by the living environment for older disabled people living in their own home and to support the care provided by paid or unpaid carers.

e) What actions are to/ or will be taken to avoid any negative impact or to better advance equality?

Requests for top-up funding for major adaptations are made by the person who has carried out the assessment with the individual.  This is usually an Occupational Therapist.  The request is made when it is known that the proposed adaptation to meet the assessed eligible need will exceed the 30K maximum DFG.  This is often after an appointed

Surveyor, Environmental Health Officer or building contractor has priced the value of the works proposed. 

The process to access capital funding where adaptations exceed 30K is clearly outlined in the major Adaptation Policy and Operational Instructions.

Practitioners present their case at Housing Solution Forums, held jointly with District and Boroughs to ensure that fair, consistent and cost effective solutions are considered when major adaptations are being proposed. 

Referrals are made through HSCC and NST teams.

Where an individual has been assessed to contribute towards the cost of the adaptation the individual needs to demonstrate that they are unable to afford the contribution.   They are asked to provide written evidence e.g.  from banks or building societies evidencing that they are unable to raise the capital required to fund their assessed contribution through equity release, re-mortgage or a person loan.

f) Provide details of the mitigation. N/A

g) How will the policy changes be monitored?

The Policy and Operational Instruction are reviewed yearly with yearly update and reminders sent to relevant practitioners. How will the effectiveness of mitigation be monitored?

4.2       Disability: Testing of disproportionate, negative, neutral or positive impact.

Consider different disabilities:

Physical Impairment, such as using arms or mobility issues.

Sensory Impairment, such as being blind or having a serious visual impairment

Mental Health Condition, such as depression or schizophrenia

Learning Disability/Difficulty, such as Down’s Syndrome or dyslexia

Long-standing illness or health condition, such as cancer or HIV, diabetes, or epilepsy

Disability discrimination by association is also prohibited, which provides protection to carers of disabled people

How is this protected characteristic reflected in the County/District/Borough?  Residents(working age only) with limiting long-term illness in 2011 by districts (numbers)

Type	All people	People with long-term health problem or disability	Day-to-day activities limited a little	Day-to-day activities limited a lot	People without long-term health problem or disability
Geography
England & Wales	56075912	10048441	5278729	4769712	46027471
South East	8634750	1356204	762561	593643	7278546
East Sussex	526671	107145	58902	48243	419526
Eastbourne	99412	20831	11209	9622	78581
Hastings	90254	19956	10375	9581	70298
Lewes	97502	19054	10583	8471	78448
Rother	90588	21242	11591	9651	69346
Wealden	148915	26062	15144	10918	122853

Residents(working age only with limiting long-term illness in 2011 by districts (%)

Type	All people	People with long-term health problem or disability	Day-to-day activities limited a little	Day-to-day activities limited a lot	People without long-term health problem or disability
Geography
England & Wales	100	17.9	9.4	8.5	82.1
South East	100	15.7	8.8	6.9	84.3
East Sussex	100	20.3	11.2	9.2	79.7
Eastbourne	100	21	11.3	9.7	79
Hastings	100	22.1	11.5	10.6	77.9
Lewes	100	19.5	10.9	8.7	80.5
Rother	100	23.4	12.8	10.7	76.6
Wealden	100	17.5	10.2	7.3	82.5

Disability Living Allowance claimants by age group in February 2012

Time period Time period	Feb-12
Broad age Broad age	Total	Percent aged under 16	Percent aged 16-59	Percent aged 60 and over
Geography Geography
Great Britain	3,267,910	10.5	50.1	39.4
South East	331,800	14.1	53.5	32.4
East Sussex	25,080	11.2	53.5	35.4

Source: Department for Work and Pensions, Longitudinal Study, NOMIS

Projected limiting long-term illness by age group, 2010-2026

Measure Measure		Number				Percent of total population
Age group Age group		All people	0-17	18-64	65+	All people	0-17	18-64	65+
Geography Geography	Year Year
East Sussex	2010	105,047	4,755	43,646	56,647	20.4	4.6	15.0	46.8
	2026	124,992	4,352	42,392	78,248	23.9	4.7	15.9	47.6

Source: ESCC projections, November 2011

Projected disability by age group, 2010-2026

Measure Measure		Number				Percent of total population
Age group Age group		All people	10-17	18-64	65+	All people	10-17	18-64	65+
Geography Geography	Year Year
East Sussex	2010	85,428	1,952	34,041	49,435	16.6	3.9	11.7	40.9
	2026	103,415	1,826	33,202	68,386	19.7	3.9	12.5	41.6

Source: ESCC projections, November 2011Employment and Support Allowance and Incapacity Benefit claimants in February 201

b) How is this protected characteristic reflected in the reflected in the population of those impacted by the proposal?

There is a potential for a positive impact on disabled people of a working age who through waiving the financial contribution in circumstances where on paper people have sufficient income (assessed by District and Borough using the national financial assessment for Disabled Facilities Grant) but in reality have heavy outgoings that may mean they are unable to get loans to cover the element of the costs of work they would be responsible for. One proposal is to waiver the necessity for individuals to apply for a loan themselves; ESCC to pay peoples assessed contribution upfront; and require weekly re-payments to recoup costs over time based on the amount they can afford to pay. 

c) Will people with the protected characteristic be more affected by the proposal, policy or strategy than those in the general population who do not share that protected characteristic?  You will need to refer to evidence gathered through monitoring and consultation in conjunction with the population statistics in a). Do you have any data available to show who will be affected by this proposal, policy or strategy? Or is this unknown due to there being no data available?

            Yes – see above

d) What is the proposal, strategy or policy’s impact on people who have a disability? Whilst there may be positive and neutral factors of the proposal, policy or strategy, which should be set out here do not try to conceal negative impacts by only highlighting the positive impacts

The proposal will have a positive impact on disabled people helping overcome the barriers to independent living and reduce risks posed by the living environment for disabled people living in their own home.

e) What actions are to/ or will be taken to avoid any negative impact or to better advance equality?

Request for top-up funding for major adaptations are made by the allocated practitioner when it appears that an adaptation will exceed the 30K maximum DFG funding. The process to access capital funding where adaptations exceed 30K is clearly outlined in the major Adaptation Policy and Operational Instructions,    Practitioners present their case at Housing Solution Forums, held jointly with District and Boroughs to ensure that fair, consistent and cost effective solutions are considered when major adaptations are being proposed.  A subsequent panel is then held with the Head of Service where a discretionary top–up funding is requested.  Focus on evidence of disproportionate impact i.e. where a decision affects a protected group more than the general population. For example disabled people are more likely to be either unemployed  or working part-time and so decisions affecting the unemployed will have a greater impact on disabled people. State how the protected group will be affected e.g. accessibility of a service? Impact on standard of living/education/leisure time etc.

f) Provide details of any mitigation. N/A

g) How will policy changes be monitored? How will the effectiveness of mitigation be monitored?

The Policy and Operational Instruction are reviewed yearly with yearly update and reminders sent to relevant practitioners & through the panel process  How will the effectiveness of mitigation be monitored?

4.3       Ethnicity: Testing of disproportionate, negative, neutral or positive       impact.

Race categories are: Colour. E.g. being black or white,

   Nationality e.g. being a British, Australian or Swiss citizen

   Ethnic or national origins e.g. being from a Roma background or of Chinese    Heritage

Not applicable- Neutral impactWhilst there may be positive and neutral factors of the proposal, policy or strategy, which should be set out here do not try to conceal negative impacts by only highlighting the positive impacts

4.4       Gender/Transgender: Testing of disproportionate, negative, neutral or            positive impact Consider men, women, transgender individuals.

a) How is this protected characteristic target group reflected in the County/District/Borough?

Not applicable- neutral impact

How will the effectiveness of mitigation be monitored?

4.5       Marital Status/Civil Partnership:Testing of disproportionate, negative,            neutral or positive impact. Marriage is defined as a 'union between a man and a woman'. Same-sex couples can have their relationships legally recognised as 'civil partnerships'.  Civil partners must be treated the same as married couples on a wide range of legal matters.

Not applicable

4.6       Pregnancy and maternity:Testing of disproportionate, negative, neutral or    positive impact. Women who are pregnant. Women within the first 26 weeks beginning with the day on which she gives birth (including stillborn)

Not applicableHow will the effectiveness of mitigation be monitored?

4.7       Religion, Belief: Testing of disproportionate, negative, neutral or positive       impact. Including Christian, Catholic, Jewish, Sikh, Hindu, Rastafarian, Muslim, Buddhist, Or similar philosophical belief Agnosticism, Atheism, Confucianism, Humanism, Taoism

Not applicable How will the effectiveness of mitigation be monitored?

4.8       Sexual Orientation - Gay, Lesbian, Bisexual and Heterosexual: Testing of disproportionate, negative, neutral or positive impact. The term gay can be used to describe a gay man and a lesbian.

Not applicable

How will the effectiveness of mitigation be monitored?

4.9 Other: Additional groups/factors that may experience impacts - testing of                   disproportionate, negative, neutral or positive impact.

• CarersThese other groups    include factors such as carers, literacy, health, rurality, poverty, - including part   time workers etc.

a) How are these groups/factors reflected in the County/District/ Borough?

Carers

b) How is this group/factor reflected in the population of those impacted by the proposal, strategy or policy?

Need for carers to have support is high.

c) Will people within these groups or affected by these factors be more affected by the proposal, policy or strategy than those in the general population who are not in those groups or affected by these factors? You will need to refer to evidence gathered through monitoring and consultation in conjunction with the population statistics in a). Do you have any data available to show who will be affected by this proposal, policy or strategy? Or is this unknown due to there being no data available?

This proposal will help overcome the barriers to independent living and reduce risks posed by the living environment for older and physical disabled people living in their own home. This will support the care provided by paid or unpaid carers and will be likely to contribute to reducing risk and have an overall positive impact on the health of carers in those households.

d) What is the proposal, strategy or policy’s impact on the factor or identified group?

There will be a positive impact on carers as above.

e) What actions are to/ or will be taken to avoid any negative impact or to better advance equality?

Request for top-up funding for major adaptations are made by the allocated practitioner when it appears that an adaptation will exceed the 30K maximum DFG funding. The process to access capital funding where adaptations exceed 30K is clearly outlined in the major Adaptation Policy and Operational Instructions,    Practitioners present their case at Housing Solution Forums, held jointly with District and Boroughs to ensure that fair, consistent and cost effective solutions are considered when major adaptations are being proposed.  A subsequent panel is then held with the Head of Service where a discretionary top–up funding is requestedFocus on evidence of disproportionate impact i.e. where a decision affects a factor or protected group more than the general population. For example those who live in very rural locations are more likely to be affected by support services being centralised. State how the protected group will be affected e.g. accessibility of a service? Impact on standard of living/education/leisure time etc?

f) Provide details of the mitigation.

Not applicable- positive impactWhat will you be able to do to mitigate any disproportionate impact?

How will the effectiveness of mitigation be monitored?

g) How will any mitigation measures be monitored? How will the effectiveness of mitigation be monitored?

The Policy and Operational Instruction are reviewed yearly with yearly update and reminders sent to relevant practitioners  

4.10        Human rights- Human rights place all public authorities – under an obligation to treat you with fairness, equality, dignity, respect and autonomy. Please look at the table below to consider if your proposal, policy or strategy may potentially interfere with a human right. At this stage take a common sense view. Any potential interference with a human right out to be flagged by your impact assessment as a possible legal non-compliance risk and bought to the attention of your Performance AD.

Articles
A2	Right to life (e.g. pain relief, suicide prevention)
A3	Prohibition of torture, inhuman or degrading treatment (service users unable to consent, dignity of living circumstances)
A4	Prohibition of slavery and forced labour (e.g. safeguarding vulnerable adults)
A5	Right to liberty and security (financial abuse)
A6 &7	Rights to a fair trial; and no punishment without law (e.g. staff tribunals)
A8	Right to respect for private and family life, home and correspondence (e.g. confidentiality, access to family)
A9	Freedom of thought, conscience and religion (e.g. sacred space, culturally appropriate approaches)
A10	Freedom of expression (whistle-blowing policies)
A11	Freedom of assembly and association (e.g. recognition of trade unions)
A12	Right to marry and found a family (e.g. fertility, pregnancy)
Protocols
P1.A1	Protection of property (service users property/belongings)
P1.A2	Right to education (e.g. access to learning, accessible information)
P1.A3	Right to free elections (Elected Members)

Part 5 – Conclusions and recommendations for decision makers

5.1       Summarise how this proposal/policy/strategy will show due regard for the three aims of the general duty across all the protected characteristics and ESCC additional groups. Having identified the specific impacts of the proposal in Part 4, this is an opportunity to show that due regard has been had to the three aims (i.e. to eliminate unlawful discrimination, harassment and victimisation, to advance equality of opportunity between people from different groups, and to foster good relations between people from different groups), by linking together the identified impacts and the mitigation measures that have been identified as necessary.Having due regard means consciously thinking about the three aims of the general duty as part of the decision making, this means that consideration of equality issues must influence decisions reached by public bodies in how we act as employers and as service providers

• Eliminate unlawful discrimination, harassment and victimisation and other conduct prohibited by the Equality Act 2010;
• Advance equality of opportunity between people from different groups

The policy changes will support independent living for disabled and older people, helping to prevent delays in necessary adaptations and essential equipment.

• Foster good relations between people from different groups

5.2       Impact assessment outcome Based on the analysis of the impact in part four please mark below ('X') with a summary of your recommendation. Having considered the potential or actual effect of your policy/strategy on equality, you should be in a position to make an informed judgement about what should be done with the policy/strategy.

X	Outcome of impact assessment	Please explain your answer fully.
	A No major change – Your analysis demonstrates that the policy/strategy is robust and the evidence shows no potential for discrimination and that you have taken all appropriate opportunities to advance equality and foster good relations between groups.	The Policy will update to reflect the changes proposed.
x	B Adjust the policy/strategy – This involves taking steps to remove barriers or to better advance equality. It can mean introducing measures to mitigate the potential effect.
	C Continue the policy/strategy - This means adopting your proposals, despite any adverse effect or missed opportunities to advance equality, provided you have satisfied yourself that it does not unlawfully discriminate
	D Stop and remove the policy/strategy – If there are adverse effects that are not justified and cannot be mitigated, you will want to consider stopping the policy/strategy altogether. If a policy/strategy shows unlawful discrimination it must be removed or changed.

5.3       What equality monitoring, evaluation, review systems have been set up to carry out regular checks on the effects of the proposal, strategy or policy? Give details If it’s a new policy or strategy and there is no evidence to suggest there might be discrimination a 6 monthly review is recommended to monitor impact. Others might included reviewing a trainingprogramme when complete, natural review of policy at 3 yearly intervals etc

The Policy and Operational Instruction are reviewed yearly with yearly update and reminders sent to relevant practitioners ‘About you’ information is also recorded on all ASC clients and will be used to identify any trends in allocation of funds by protected characteristics. This will be overseen by the Operational Head of Service Adult Social Care.

5.6       When will the amended proposal, strategy or policy be reviewed? Include dates for completion and Manager(s) responsible

April 2024

Date completed:	3^rd February 2021	Signed by (person completing)	Michelle Crouch
		Role of person completing	Principal Occupational Therapist
Date:	3^rd February 2021	Signed by (Manager)

Part 6 – Equality impact assessment action plan The team should keep a copy of the improvement plan to initiate any proposed changes to initiate any proposed changes and identify any risks for the organisation and incorporate them into the performance management process for their department

If this will be filled in at a later date when proposals have been decided please tick here and fill in the summary report.

The table below should be completed using the information from the equality impact assessment to produce an action plan for the implementation of the proposals to:

1. Lower the negative impact, and/or
2. Ensure that the negative impact is legal under anti-discriminatory law, and/or
3. Provide an opportunity to promote equality, equal opportunity and improve relations within equality target groups, i.e. increase the positive impact
4. If no actions fill in separate summary sheet.

Please ensure that you update your service/business plan within the equality objectives/targets and actions identified below:

Remove negative impacts for people with protected characteristics

Improve opportunities for people with protected characteristics

Improve evidence to fill in 'gaps' in knowledge

Record any changes already made as a result of the impact assessment

Actions resulting from public engagement, should include the name and date of the engagement next to it

Area for improvement	Changes proposed	Lead Manager	Timescale	Resource implications	Where incorporated/flagged? (e.g. business plan/strategic plan/steering group/DMT)
Cascade of the revised Major Adaptation Process updating staff on the changes	ASC funding of assessed contribution	Michelle Crouch	April 2024	None	DMT
Monitoring trends in allocation by protected characteristics	Oversight of About You information	Michelle Crouch	Annual with review of policy operation	None	DMT
Update guidance to staff and public on the changes to assessed contribution	Guidance and Public Information	Michelle Crouch	April 2022	None	DMT

From your analysis please identify any risks not addressed giving reasons and how this has been highlighted within your Directorate:

Area of Risk

Type of Risk?  (Legal, Moral, Financial)

Can this be addressed at a later date? (e.g. next financial year/through a business case)

Where flagged? (e.g. business plan/strategic plan/steering group/DMT)

Lead Manager

Date resolved (if applicable)