Equality impact assessment (EIA) form: evidencing paying due regard to protected characteristics

(Form updated April 2019)

Household Support Fund

If you would like this information in another language or format such as Braille, large print or audio, please contact the Communications Unit on 01609 53 2013 or email communications@northyorks.gov.uk.

Equality Impact Assessments (EIAs) are public documents.  EIAs accompanying reports going to County Councillors for decisions are published with the committee papers on our website and are available in hard copy at the relevant meeting.  To help people to find completed EIAs we also publish them in the Equality and Diversity section of our website.  This will help people to see for themselves how we have paid due regard in order to meet statutory requirements. 

Name of Directorate and Service Area	Central Services
Lead Officer and contact details	Neil Irving neil.irving@northyorks.gov.uk
Names and roles of other people involved in carrying out the EIA	Adele Wilson-Hope
How will you pay due regard? e.g. working group, individual officer	Steering Group
When did the due regard process start?	1 October 2022

Section 1. Please describe briefly what this EIA is about.

£421 million has been made available to County Councils and Unitary Authorities in England between October 2022 and March 2023 to support households most in need, particularly those who may not have been eligible for other government support made available.  This includes the Cost of Living payments set out on 26 May 2022, and the energy support set out on 3 February 2022 (and enhanced on 26 May 2022) and detailed on 29 July 2022.  The fund is however intended to cover a wide range of low income households in need, including families with children of all ages, pensioners, unpaid carers, care leavers and disabled people.     

The expectation is that HSF should be primarily used to support households in the most need with the costs of energy, however it can also be used to support households with the cost of food and water bills, essential costs related to those items, and with wider essential costs.

North Yorkshire County Council will receive an allocation of £3,537,549.92. The timing of the announcement and the public expectation that the scheme will be available for applications, means that prompt action is necessary to deliver the scheme as soon as possible.

Section 2. Why is this being proposed? What are the aims? What does the authority hope to achieve by it? (e.g. to save money, meet increased demand, do things in a better way.)

HSF should be primarily used to support households in the most need with the costs of energy, however it can also be used to support households with the cost of food and water bills, essential costs related to those items, and with wider essential costs.

Support should be targeted at the following households:

i. Those who may not be eligible for government support that has been made available but who are in need. This includes the Cost of Living Payments set out on 26 May 2022 and the energy support set out on 3 February (enhanced on 26 May 2022), and detailed on 29 July 2022. This may include, but is not limited to, people who are entitled to but not claiming qualifying benefits, people who are claiming Housing Benefit (HB) only, people who begin a claim or return to payment of a benefit after the relevant qualifying date, as well as people who have fuel costs but who cannot access the £400 of energy support from the Energy Bill Support Scheme or the equivalence package confirmed on 29 July 2022.

ii. Those who are vulnerable to rising prices even though they are supported through these schemes, for example large families or single-income families.

iii. Those from a range of low income households in need including families with children of all ages, pensioners, unpaid carers, care leavers and disabled people.

Eligible expenditure includes:

· Energy and water. The fund should primarily be used to support energy bills for any form of fuel that is used for the purpose of domestic heating, cooking, or lighting, including oil or portable gas cylinders. It can also be used to support water bills including for drinking, washing, cooking, as well as for sanitary purposes and sewerage.

· Food. The fund can be used to provide support with food, whether in kind or through vouchers or cash.

· Essentials linked to energy and water. The fund can be used to provide support with essentials linked to energy and water (for example period products, warm clothing, soap, blankets, the purchase of equipment such as fridges, freezers, ovens, slow cookers), in recognition that a range of costs may arise which directly affect a household’s ability to afford or access energy, food and water. This may also include supporting households on low incomes to repair or replace white goods and appliances with more energy efficient ones, or to invest in simple energy efficiency measures which will pay back quickly, such as insulating a hot water tank, fitting draft excluders to a front door, or replacing inefficient lightbulbs or white goods. The intention of this is to provide sustainable support which could result in both immediate and long-lasting savings for the household.

· Wider essentials. The fund can be used to support wider essential needs not linked to energy and water should Authorities consider this appropriate in their area. These may include, but are not limited to, support with other bills including broadband or phone bills, clothing, and essential transport-related costs such as repairing a car, buying a bicycle, or paying for fuel. This list is not exhaustive.

· Housing costs. In exceptional cases of genuine emergency, where existing housing support schemes do not meet this exceptional need, the fund can be used to support housing costs. Where eligible, ongoing housing support for rent must be provided through the Housing cost element of Universal Credit (UC) and Housing Benefit (HB) rather than the fund. In addition, eligibility for Discretionary Housing Payments (DHPs) must first be considered before emergency housing support is offered through the fund. The Authority must also first consider whether the claimant is at statutory risk of homelessness and therefore owed a duty of support through the Homelessness Prevention Grant (HPG).

· In exceptional cases of genuine emergency, households in receipt of HB, UC, or DHPs can still receive housing cost support through the fund if it is deemed necessary by their Authority. However, the fund should not be used to provide housing support on an ongoing basis or to support unsustainable tenancies.

· Individuals in receipt of some other form of housing support could still qualify for the other elements of the fund, such as food, energy, water, essentials linked to energy and water and wider essentials.

· The fund cannot be used to provide mortgage support, though homeowners could still qualify for the other elements of the fund (such as energy, food, water, essentials linked to energy and water and wider essentials).

· The fund can exceptionally and in genuine emergency be used to provide support for historic rent arrears built up prior to an existing benefit claim for households already in receipt of UC and HB. This is because these arrears are excluded from the criteria for DHPs. However, support with rent arrears is not the primary intent of the fund and should not be the focus of spend.

· Reasonable administrative costs for administering the fund.

Section 3. What will change? What will be different for customers and/or staff?

The North Yorkshire eligibility framework and approach is intended to recognise the current cost of living pressures including inflationary pressures on essential goods and services in particular gas, electricity and other fuel costs over the next 6 months.

Section 4. Involvement and consultation (What involvement and consultation has been done regarding the proposal and what are the results? What consultation will be needed and how will it be done?)

No requirement for formal consultation.

A governance structure has been established to oversee the development and delivery of this phase of HSF.  Board membership includes:

Neil Irving - NYCC

Abby Barker - NYCC

Adele Wilson-Hope – NYCC

Marcus Lee - Ryedale DC

Sarah Foley - NYCC

Linda Porritt - NYCC

Helen Knisis – NYCC

Amber Graver - NYCC

A project team and 4 additional work packages (Communications, Customer Service, Operations - Revenues and Benefits and Technical Product) also support the Board structure.  These include officers from district and borough councils.

Section 5. What impact will this proposal have on council budgets? Will it be cost neutral, have increased cost or reduce costs?

Cost neutral, as all costs covered by HSF allocation. This includes reasonable administrative costs incurred if claimed. Administration activity may include:

- Staff Costs

- Advertising and publicity to raise awareness

- Small IT changes eg to facilitate MI production

Section 6. How will this proposal affect people with protected characteristics?	No impact	Make things better	Make things worse	Why will it have this effect? Provide evidence from engagement, consultation and/or service user data or demographic information etc.
Age				The grant determination for the third phase of HSF outlines that support for low income families in need, including those with a person of state pension age should be considered.  It is intended as part of the programme to directly award support to eligible pensioner households.
Disability
Sex
Race
Gender reassignment
Sexual orientation
Religion or belief
Pregnancy or maternity
Marriage or civil partnership

Section 7. How will this proposal affect people who…	No impact	Make things better	Make things worse	Why will it have this effect? Provide evidence from engagement, consultation and/or service user data or demographic information etc.
..live in a rural area?
…have a low income?				All funds are to be targeted to support households in the most need with energy, food and water bills. It can also be used to support with essential costs related to those items and with wider essential costs.
…are carers (unpaid family or friend)?

Section 8. Geographic impact – Please detail where the impact will be (please tick all that apply)
North Yorkshire wide
Craven district
Hambleton district
Harrogate district
Richmondshire district
Ryedale district
Scarborough district
Selby district
If you have ticked one or more districts, will specific town(s)/village(s) be particularly impacted? If so, please specify below.

Section 9. Will the proposal affect anyone more because of a combination of protected characteristics? (e.g. older women or young gay men) State what you think the effect may be and why, providing evidence from engagement, consultation and/or service user data or demographic information etc.

N/A

Section 10. Next steps to address the anticipated impact. Select one of the following options and explain why this has been chosen. (Remember: we have an anticipatory duty to make reasonable adjustments so that disabled people can access services and work for us)	Tick option chosen
1. No adverse impact - no major change needed to the proposal. There is no potential for discrimination or adverse impact identified.	a
2. Adverse impact - adjust the proposal - The EIA identifies potential problems or missed opportunities. We will change our proposal to reduce or remove these adverse impacts, or we will achieve our aim in another way which will not make things worse for people.
3. Adverse impact - continue the proposal - The EIA identifies potential problems or missed opportunities. We cannot change our proposal to reduce or remove these adverse impacts, nor can we achieve our aim in another way which will not make things worse for people. (There must be compelling reasons for continuing with proposals which will have the most adverse impacts. Get advice from Legal Services)
4. Actual or potential unlawful discrimination - stop and remove the proposal – The EIA identifies actual or potential unlawful discrimination. It must be stopped.
Explanation of why option has been chosen. (Include any advice given by Legal Services.)

Section 11. If the proposal is to be implemented how will you find out how it is really affecting people? (How will you monitor and review the changes?)

The DWP provide a monitoring and delivery framework for expenditure. The data will be collected at 2 intervals. The first monitoring return will be submitted in January 2023. This mid-point review will enable the Council to determine how many households are applying for the various grants and that the grant is reaching the intended beneficiaries. If there is lower than anticipated take up of the grant further contact will be made with the eligible households to encourage take up.

The second monitoring return is April 2023 which will report on the overall spend profile and track delivery progress in accordance with DWP monitoring requirements. .

Section 12. Action plan. List any actions you need to take which have been identified in this EIA, including post implementation review to find out how the outcomes have been achieved in practice and what impacts there have actually been on people with protected characteristics.
Action	Lead	By when	Progress	Monitoring arrangements
DWP MI Return	Adele Wilson-Hope	25 January 2023
DWP MI Return	Adele Wilson-Hope	28 April 2023

Section 13. Summary Summarise the findings of your EIA, including impacts, recommendation in relation to addressing impacts, including any legal advice, and next steps. This summary should be used as part of the report to the decision maker.

The delivery plan for the distribution of the HSF has been developed and agreed by a range of stakeholders and partners in order to ensure it is fair and equitable and designed to ensure the grant reaches the intended beneficiaries - households on low incomes and in particular those who in receipt of housing benefit who did not receive a cost of living payment.

The distribution will be monitored to ensure it is reaching the intended beneficiaries and actions will be taken at the review point if there is low take up to contact eligible households.

Arrangements will be in place (including through libraries, district and borough councils, and community support organisations) to ensure households who need additional help to access or utilise vouchers are able to do so.

Section 14. Sign off section

This full EIA was completed by:

Name:  Neil Irving

Job title:  Assistant Director – Policy, Partnerships and Communities

Directorate:  Central Services

Signature: Neil Irving

Completion date:  25 November 2022

Authorised by relevant Assistant Director (signature):  Neil Irving

Date:  25 November 2022