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

(form updated June 2023)

Household Support Fund (Phase 5)

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 find completed EIAs, we also publish them in our website's Equality and Diversity section.  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	Margaret Wallace margaret.wallace@northyorks.gov.uk
Names and roles of other people involved in carrying out the EIA	Adele Wilson-Hope
How will you pay due regard? for example, working group, individual officer	HSF Project Board
When did the due regard process start?	1^st April 2024

Section 1. Please describe briefly what this EIA is about. (for example, are you starting a new service, changing how you do something, stopping doing something?)

On 6 March 2024 the Chancellor announced in the Spring Budget that £421m has been made available to County Councils and Unitary Authorities in England to support those most in need with the cost of essentials via a fifth phase of the Household Support Fund (HSF).

HSF should be used to support households in the most need with the cost of essentials over the next 6 months.  This encompasses a wide range of low-income households in need, including families with children of all ages, pensioners, unpaid carers, care leavers and disabled people, larger families, single-person households, and those struggling with one-off financial shocks or unforeseen events.

The expectation is that HSF should be used to meet immediate need and support those who are struggling to afford household essentials including energy and water bills, food and wider essentials.  Funding can also be used to support households with housing costs where existing housing support does not meet this need, and to supplement support with signposting and advice.  

Although this is informally considered an extension to the previous four Household Support Fund schemes, it is a new grant subject to its own grant conditions as is set out in the Grant Determination letter. North Yorkshire 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.

This funding covers the period 1 April 2024 to 30 September 2024 inclusive.

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

Support should be extended to a wide range of low-income households in need, including families with children of all ages, pensioners, unpaid carers, care leavers and disabled people, larger families, single-person households, and those struggling with one-off financial shocks or unforeseen events.

Eligible expenditure includes:

· Energy and water.  This may include support with 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, water and food (for example insulation or energy efficient items which reduce bills, the purchase of equipment such as fridges, freezers, ovens, slow cookers or costs associated with obtaining these essentials such as delivery and installation).  Authorities are encouraged to consider 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 energy inefficient lightbulbs or white goods. The intention of this is to provide sustainable support which results in immediate and potentially long-lasting savings for the household.

· Wider essentials. HSF can be used to support wider essential needs not linked to energy, water or food 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, period and hygiene products, essential transport-related costs such as repairing a car, buying a bicycle, or paying for fuel.  This list is not exhaustive.  It can also include one-off payments to prevent a crisis.

· Advice services. HSF may be used to provide supplementary advice services to award recipients, including debt, benefit and/or employment advice, where Authorities consider this appropriate and where it complements the objectives and practical delivery of HSF.

· Housing costs. HSF can be used to provide support with housing costs to those in need. However, where eligible, ongoing housing support for rent must be provided through the Housing cost element of UC and Housing Benefit (HB) rather than HSF. In addition, eligibility for Discretionary Housing Payments (DHPs) must first be considered before housing support is offered through HSF.  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). It is expected that the focus of support should be on bills and that support for housing costs should only be given where existing housing support schemes do not meet need. Beyond this, Authorities have discretion to determine the most appropriate use of HSF for their area, based on their understanding of local need and with due regard to equality considerations.

- Households in receipt of HB, UC, or DHPs can still receive housing cost support through HSF if it is deemed necessary by their Authority. However, it 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 HSF, such as food, energy, water, essentials linked to energy and water and wider essentials.

- HSF 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 and management 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 on essential goods and services 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:

Margaret Wallace – Customer, Revenues & Benefits

Suzanne Truman – Finance

Adele Wilson-Hope – Stronger Communities

Marcus Lee – Welfare & Benefits

Guy Shrimpton – Welfare & Benefits

Sarah Foley – Customer Services

Helen Tumilty – Customer Services

Craig Ryan – Customer Services

Linda Porritt – Financial Assessment & Benefits

Helen Knisis – Communications

Amber Graver – Stronger Communities

Hazel Smith - Libraries

Ian Grayson – Data & Intelligence

Palbinder Mann - Technology

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 locally based, and specialist teams.

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 e.g. 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 fifth phase of HSF outlines that support for low income families in need, and those with a person of state pension age should be considered.  It is intended as part of the programme to directly award support to both families and eligible pensioner households.
Disability				Disabled people in particular may be facing acute challenges to meet additional needs in order to manage their conditions, remain independent and avoid becoming socially isolated. For example, some disabled people may have increased utility bills due to the usage of equipment, aids or adaptations associated with their disability. They may also have additional heating, water or transport costs.
Sex
Race
Gender reassignment
Sexual orientation
Religion or belief
Pregnancy or maternity				Those who fall within this group and receive an allocation may have additional food or fuel requirements due to their pregnancy or maternity status.
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?				Additional income to those who receive an allocation and live in a rural area may see higher costs to access food due to having to travel further distances to get food. Also those in rural areas may have higher energy costs due to limited sources of fuel available to heat their homes with many houses not on mains gas and poorly insulated homes due to the type of housing found in rural areas.
…have a low income?				The Fund is 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, larger families, single-person households, and those struggling with one-off financial shocks or unforeseen events.
…are carers (unpaid family or friend)?				Care leavers can face particular barriers as they leave the care system and begin to live independently. For example, care leavers may not have access to the same familial networks as others in their cohort and subsequently will not have the same financial, emotional or social support systems that enable them to live independently, respond to crisis or avoid becoming socially isolated. People with caring responsibilities may be facing acute challenges incurred through their fulfilling these responsibilities for vulnerable citizens. For example, they may have additional heating, water or transport costs.
….. are from the Armed Forces Community				Although not a targeted/priority group for the fund, those from the Armed Forces Community will be able to access support.

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

Section 9. Will the proposal affect anyone more because of a combination of protected characteristics? (for example, 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.

Through insight gathered from the delivery of the previous 4 phases of HSF, NYC are aware of households that are impacted by a combination of protected characteristics, for example Age and Disability.  This has been a key consideration when developing the non-digital offer, and supporting those who are elderly and disabled, and who may be housebound as well as digitally excluded.  A Customer Voice survey undertaken in March 2024 has confirmed that 83% of recipients wouldn’t change anything about the scheme, with a 96% satisfaction level; confirming that the support offer is largely appropriate for the cohort we are working with.  

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 is needed to the proposal. There is no potential for discrimination or adverse impact identified.
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 the option has been chosen (include any advice given by Legal Services.) Guidance has been provided by the Government that describes the scheme and the parameters to which it is to be administered.

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 July 2024. Quarterly reviews 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 vouchers via the direct award, then further contact will be made with the eligible households to encourage take up.  The final monitoring return is October 2024 which will report on the overall spend profile and track delivery progress in accordance with DWP monitoring requirements.

In line with previous rounds, light touch evaluation will be completed in September 2024, including a customer voice exercise. 

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	Margaret Wallace	19 July 2024
DWP MI Return	Margaret Wallace	25^th October 24
Evaluation	Margaret Wallace	September 2024

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 – a wide range of low-income households in need, including families with children of all ages, pensioners, unpaid carers, care leavers and disabled people, larger families, single-person households, and those struggling with one-off financial shocks or unforeseen events  This will be signed off by the Executive Member for Corporate Services and the Section 151 Officer prior to submission to the DWP.

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 of support made available.

Arrangements will be in place (including through libraries, customer service access points and where appropriate, through key community partners) 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: Margaret Wallace

Job title: Assistant Director – Customer, Revenues & Benefits

Directorate: Central Services

Signature: Margaret Wallace

Completion date: 15 April 2024

Authorised by relevant Assistant Director (signature): Margaret Wallace

Date: 15 April 2024