Extra Care - Equality impact assessment (EIA)

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 the Directorate and Service Area	Procurement, Partnerships and Quality Assurance
Name of the service/policy being assessed	Extra care housing delivery programme
Is this the area being impact assessed a	Policy and its implementation?	x	Service?
	Function		Initiative?
	Project?		Procedure and its implementation?
Is this an Equality Impact Assessment for a (Note: the Equality Impact Assessment (EIA) is concerned with the policy itself, the procedures or guidelines which control its implementation and the impact on the users)	Existing service or a policy and its implementation?
	Proposed service or a policy and its implementation?
	Change to an existing service or a policy and its implementation?			x
	Service or policy carried out by an organisation on behalf of us?
How will you undertake the EIA? Eg team meetings, working party, project team, individual Officer	Individual officer, in consultation with project teams and work colleagues.
Names and roles of people carrying out the Impact Assessment	Rebecca Dukes Project Officer ECH Juliette Daniel, Head of Extra Care
Lead Officer and contact details	Juliette Daniel : juliette.daniel@northyorks.gov.uk 01609798662
Date EIA started	May 2011
Date EIA Completed	Final draft for quality assurance: 24 June 2011
Sign off by Service Head/ Business Unit Head
Sign off by Assistant Director (or equivalent)
Date of Publication of EIA
Monitoring and review process for EIA

1. Operating Context

Please consider issues around impacts (positive or negative) raised for all protected characteristics and show your evidence.

1.1 Describe the service/policy

What does the service/policy do and how? How would you describe the policy to someone who knows very little about council services?

We currently have 9 elderly persons homes earmarked for potential replacement although this reduced to 8 following the executive decision (8 March 2011) regarding Harrogate extra care. The ‘housing needs analysis – accommodation with care’ has identified a need for an additional 30 extra care schemes across the County by 2020 to meet existing and future demand.

If there is a proposal to change the service or policy, describe what it looks like now and what it is intended to look like in the future. What are the drivers for this proposed change?

In November 2010, officers presented to executive members four options for the future of elderly persons’ accommodation in North Yorkshire. The main options were to close all 9 county council-owned elderly persons’ homes (EPHs) without replacement, or to replace all 9 elderly persons’ homes with extra care housing schemes. The outcome of that meeting was that executive members would prefer to re-place the elderly persons’ homes with extra care housing.

Who does it benefit? What are its intended outcomes? Who is affected by the policy? Who is intended to benefit from it and how? Who are the stakeholders? identify those protected characteristics for which this service is likely to have an impact (positive or negative)

Option 3 of the appraisal suggested a procurement exercise be conducted to meet the demands as identified in the housing needs analysis.

In March 2011, executive members agreed to pursue the procurement exercise option, to potentially deliver 30 additional schemes across North Yorkshire.

Are there any other policies or services which might be linked to this one? Have you reviewed the EIA for these policies/services? What do they tell you about the potential impact?

We have a commissioning strategy that will ensure that older and vulnerable people across North Yorkshire have access to a range of accommodation and services, such as:-

• retaining 6 of our resource centres across the county
• providing extra care housing in major towns and villages across the county
• nursing home provision in the independent sector
• specialist housing such as for people living with dementia, physical or learning disability in both the extra care schemes and in the independent sector
• encouraging district and borough partners to ensure any new housing meets Lifetime Homes Standards so that people can remain in their home as their needs change
• supporting people to remain at home utilising Telecare

The availability of capital grant to support the delivery of extra care housing has diminished severely and there is a need to identify more innovative ways to enable extra care development to continue.

How will the policy be put into practice? Who is responsible for it?

The extra care team has undertaken market testing in the form of an open meeting with potential providers followed by submission of initial proposals. These were considered by a project board consisting of senior officers who also sought legal advice regarding specific aspects of some of the proposals.

The market testing led to the development of a list of outcomes and a second round of market testing has led to the submission of 7 proposals with a varying level of detail. An additional outcome of the robust market testing that has been undertaken is the fact that we have been able to be much more demanding in our requirements and desired outcomes. 

Developers and specialist extra care housing associations are keen to increase their offer in order to secure development business within the poor market conditions that currently exist.

It is clear from the results of the market testing that this process would generate a number of benefits for us far and above just meeting the needs of adult and community services. As well as re-providing our elderly persons homes and delivering extra care housing to meet existing and future need, the project would deliver:-

Economic development

• this project would facilitate stimulation of a market that is currently in decline
• it would enable organisations that are currently reducing their development programmes to kick-start development across the county and provide training and employment opportunities
• it would enable social enterprise opportunities to provide training and employment to people who can’t access these through traditional routes such as people with a learning or physical disability or people in isolated rural communities
• the extra care housing schemes will be much larger than the existing elderly persons home’ s and will therefore offer higher numbers of employment opportunities than currently available
• undertaking this project would identify us as a national lead in enabling development to continue by utilising an innovative and creative model

An overarching EIA has been completed for the delivery of extra care housing in North Yorkshire and also, where an elderly persons home is identified for replacement, an EIA has been undertaken, which is included in The Planned Closure of a Residential Home Procedure.

Where the identified elderly persons homes are considered for replacement, the above mentioned procedure and EIA will be adopted.

Regardless of which option Executive Members agree to continue with, i.e. whether to work in partnership to deliver 30 further schemes or to only replace the 8 elderly persons home with extra care housing, the decision to consult to replace these elderly persons homes has already been ratified.

The development programme for 30+ schemes will enable people in North Yorkshire to access extra care housing in wider locations, than if we only developed extra care housing linked to the 9 elderly persons homes.

1.2 How do people use the policy/service?

How is the policy/service delivered? How do people find out about the policy/service? Do they need specialist equipment or information in different formats? How do you meet customer needs through opening times/locations/facilities? Can customers contact your service in different ways? How do you demonstrate that your service/policy is welcoming to all groups within the community?

Where the provision of other services are linked to the replacement of an elderly persons home, The closure of a residential home EIA will be adopted and the impact identified on people in terms of their protected characteristics.

Does the policy/service support customers to access other services? Do you charge for your services? Do these changes affect everyone equally? Do some customers incur greater costs or get 'less for their money'? Are there eligibility criteria for the service/policy?

When considering changes to other community services, equality analysis for that specific service will be carried out to identify the impact on people using those services.

How do you ensure that staff/volunteers delivering the service follow the council’s equality policies? Does the council deliver this policy in partnership or through contracts with other organisations? How do you monitor that external bodies comply with the council's equality requirements? 

There is currently a project team reviewing our other services. Any proposals to change these services will prompt consultation and discussion with the people using those services, to establish how best to re provide them, taking into consideration people’s needs and choices.

2. Understanding the impact (using both qualitative and quantitative data)

Please consider issues around impacts (positive or negative) raised for all protected characteristics and show your evidence.

2.1 What information do you use to make sure the service meets the needs of all customers?

For locality specific data, people aged 18-64 years and 65 years and over, including gender, ethnicity, religion (65 years+), dementia, learning disability, physical disability, hearing impairment, sight impairment, age profiles, distribution of population by ward and long term limiting illness by ward.

What data do we use now? Is it broken down across protected characteristics (and are these categories consistent across all data sets)? How current is the data? Where is it from? Is it relevant?

To date, the allocation processes for existing schemes and the housing needs analysis for extra care housing in North Yorkshire show that there is a demand for additional extra care housing schemes to meet the housing and care needs of local communities. The data collated from the mapping exercise carried out in 2010 is captured in the housing need analysis.

What engagement work have you already done that can inform this impact assessment? Who did you talk to and how? What are the main findings? Can you analyse the results of this consultation across the protected characteristics? Are there differences in response between different groups? How has this changed the plans for the policy/service?

Generally the schemes have full occupancy levels with considerable waiting lists. The waiting list often includes people who are applying to a scheme from out of area, where there is no extra care housing scheme available to them, highlighting that the proposal to deliver 30 further schemes will mean that people are more likely to be able to access extra care housing in the communities in which they live, without having to move away from family and friends. Eligibility criteria to the current schemes prioritises local people and then people with a local connection, therefore these people are limited in their options and often do not get the opportunity to be allocated an apartment. It also presents a challenge to the allocations panel when trying to prioritise people’s needs.

In terms of the protected characteristics, all applicants are treated equally and priority to allocate is given on housing and care needs. The allocation panel are only supplied with names and assessments of care needs rather than specific characteristics.

Scheme reviews undertaken in 2009 indicated that extra care housing schemes do not have diverse religious services, although they do provide a non-denominational type service. If this was identified as a need for specific individuals, arrangements could be put in place to support access to faith-based activities e.g. via community liaison. For some individuals, this might form part of their support plan.

Information regarding ethnicity was captured in the reviews carried out in 2009, and highlighted that there are no tenants from BME groups living in extra care housing schemes at present.

2.2 What does the information tell you?

Are there any differences in outcome for different groups e.g. differences in take up rates or satisfaction levels across groups? Does it identify the level of take-up of services by different groups of people? Does it identify how potential changes in demand for services will be tracked over time, and the process for service change?

Demographic data indicates that the population of people aged 65+ is expected to increase in all districts/boroughs across North Yorkshire.

Taking into consideration the expected rise in the older population over the next 10 years and the increase in other people requiring support services from us, as well as changes in legislation regarding how services should be delivered to people, we need to be proactive and innovative when considering how its services are provided to people.

We need to ensure that its services meet the needs of the population, including any equality and diversity factors, and that the services they provide are accessible and offer value for money for both the organisation and the people using the services.

The recent spending review and the financial restraints imposed by the government presents challenges to the delivery of all services, particularly when considering the size of the county and the rural nature, with many isolated communities and hard to reach people. Traditional methods of delivering services are no longer viable, in terms of finances and people’s expectations.
 
At present extra care housing is primarily focussed on accommodation for older people usually 55 plus. The mapping exercise carried out in 2010 shows evidence that there is a need for future extra care housing to meet a range of needs and ages rather than concentrating on supporting one particular client group. Evidence from current extra care housing allocation groups across North Yorkshire suggests there is a need to expand the eligibility criteria to include other groups of people. Often people below the age criteria apply, and although applicants are discussed on an individual basis, there are concerns about placing younger adults in predominantly older people’s facilities, particularly where the type of social activities are generally decided by the residents, who would be, at this moment, an older age group and with probably a different type of social life to a younger adult.

The need for accommodation with care for people with learning and physical disabilities has been identified through the mapping exercise as well as the nomination and allocation process. The current process is based on the panel members considering whether the applicant’s physical, emotional and social wellbeing would be met by moving into the scheme. It is sometimes deemed not appropriate for a younger person to move into a scheme which is fully occupied by older people even though the physical layout of the building is appropriate to their needs. 

Our future vision is to give all vulnerable adults the opportunity to access extra care housing where it is their wish to do so. It is acknowledged that a range of housing options needs to be available to people. It is intended that the extra care housing programme be delivered without homes and communities agency grant, thereby enabling any available grant to be used to fund other housing types. A need has been identified through the mapping process for accommodation for other groups i.e. people living with dementia and other cognitive impairment. Consideration will need to be given to how consultation will be carried out with these people.

The procurement process, for the delivery of 30 further schemes, if agreed by executive members, will continue over the next 12-18 months. The outcome of these proposals, with the appointment of a partner will be expected to be completed in Jan 2013. The development of these proposed schemes will deliver in total 1,500 units, maximising the number of units on each site, whereas our residential homes currently provide approximately 315 beds. The wider availability of specialist accommodation will be of benefit to vulnerable people living in the identified locations, giving them more choice about their housing and care needs as well as benefitting the local community, with facilities for them to utilise in the schemes.

The delivery of extra care housing in North Yorkshire is directly linked to the replacement of our elderly persons’ homes, therefore existing residents of North Yorkshire’s elderly persons homes are directly affected due to the replacement of their current accommodation with extra care housing. When an existing elderly persons home is earmarked for closure, residents are either given the option of transferring over to extra care housing, with either a right to return or right to access, or to be placed in another residential establishment, usually in the independent sector.

Along with our partner organisations, we make sure that our marketing and allocations process is inclusive of all people from diversity groups. Any issues relating to the closure of a specific elderly persons home would be identified through the application of the closure of A residential home procedure.

Although current residents in elderly people housings are directly affected they also benefit in terms of having the opportunity to move into more appropriate accommodation with facilities and support to suit their needs as well as giving security of tenure and the opportunity to maximise their financial status. Extra care housing is able to support people with changing care and support needs, in partnership with health and housing partners. 

Due to the design layout of the schemes and the use of telecare technology, people with very high support needs are able to stay in their accommodation for longer than may have been the case in traditional residential care. People living in the local community benefit from being given the opportunity of an alternative housing option with care support rather than institutional type residential care. 

It is clear that the EIA for this project cannot be and should not be completed in isolation from other projects or activities that are taking place within the directorate. Consideration needs to be given to these projects and activities and their associated EIAs to ensure that any inter-dependencies are taken into account. Some examples of these activities are:

• personalisation
• domiciliary care
• elderly people's housing closures
• night service
• LD transformation
• housing related support
• day care
• short stay

2.3 Are there areas where we need more information? How could we get this information?

More information is required to inform the reviewing of services, which is currently underway, establishing how changes to the delivery of services will impact on the people using these services. Equality analysis will need to be completed for each of these services to consider issues around the impacts (positive or negative) raised for all protected characteristics.

What data is available? Do other directorates, partners or other organisations hold relevant information? Is there relevant information held corporately e.g. compliments and complaints? Are there national datasets that would be useful? Is there relevant census data? Do you need to collect more data? How could you do this?

Census data available on the office of national statistics website as well as information provided through the POPPI website  and PANSI website can be utilised to consider where engagement is required with people from the protected characteristics groups both for the delivery of extra care housing and where services are being reviewed. We will continue to engage with local community groups and make use of local knowledge.

Do you need to do more engagement work to inform this impact assessment? Have you identified information in other sections of this EIA that you need to assess the impact on different groups of people? What do you want to find out? Which existing mechanisms can you use to get this information?

For extra care housing delivery, it will support the team to consider what type of facilities might be needed in specific locations i.e. support for people living with dementia. This will take place on an individual basis for each scheme and be specific to each locality. Community information events will take place, which will give people the opportunity to feed back comments and issues, and make suggestions about facilities which would help the local community.

For proposed changes to other services, collection of data will support the team to identify where higher concentrations of people from the protected characteristics groups are located and how best to re-provide services to those people. We understand that the information these data sources can provide is limited, particularly where there are very small numbers of people from some groups (e.g. minority ethnic people, lesbian, gay and bisexual people, or people of non-Christian faiths). We will make sure that our approaches are inclusive of people from protected characteristics groups who may be in small numbers or living in comparative isolation (e.g. in rural areas), and who are therefore harder to identify via quantitative data sources.

The inclusion of existing community groups and forums would be beneficial to both projects and paramount to ensuring that services are delivered to the right people and in the right locations and give people the option of telling us how they wish their services to be provided.

2.4 How will you monitor progress on your policy/service, or take-up of your service?

Our design and Ethos guide will provide our identified partner with our ambitions for future extra care housing schemes and the level of service expected to be provided to people living in North Yorkshire. By adopting this guide, we will ensure that ECH schemes will deliver services suitable to a community’s needs.

What monitoring techniques would be most effective? What performance indicators or targets would be used to monitor the effectiveness of the policy/service? How often does the policy/service need to be reviewed? Who would be responsible for this?

Evaluation processes are incorporated into project delivery plans and will be carried out by the extra care housing team.

A quality assurance framework is in the process of being developed, by the review project team, for regulated services.

The quality assurance framework (QAF) requires the provider to evidence their practice against a range of objectives and outcomes. This will be undertaken as a self assessment audit by the provider on an annual basis.

The review team are also producing a statement of intent, covering objectives and principles for purchasing domiciliary care services to ensure that providers are able to demonstrate an acceptable level of quality initially through CQC ratings and then a sustained level of quality validated by the quality assurance framework (QAF).

3. Assessing the impact

Please consider issues around impacts (positive or negative) raised for all protected characteristics and show your evidence.

3.1 Has an adverse impact been identified for one or more groups?

The option to replace our elderly persons homes will have an impact on older people, effectively reducing their options for residential care support directly provided by us. The group most affected and who may experience some adverse impact would be those older people currently resident in our directly-provided care homes and people in rural areas where independent residential care provision is limited.

However, the option to provide with extra care housing will benefit older people by providing them with better access to an improved ‘accommodation with support’ option, and those people who are currently resident in care homes that are marked for closure will have choice of alternative accommodation options and their individual needs considered.

If approved, the wider programme of development of extra care housing would have a positive impact on a wider group of people from the protected characteristics i.e. people with physical and learning disabilities or dementia, by providing them with more choices around housing and care support. The more extra care housing schemes that are developed across the county, the more people will benefit.

Has this assessment shown anything in the policy, plan or service that results in (or has the potential for) disadvantage or discrimination towards people of different groups? Which groups?

Do some needs/ priorities ‘miss out’ because they are a minority not the majority? Is there a better way to provide the service to all sections of the community?

It has been acknowledged that changes to eligibility criteria are essential to ensure that all vulnerable people have the option to access extra care housing and that the extra care housing design and ethos guide are adopted by partners to ensure that the environment in which these vulnerable people are living is suitable to their needs.

The impact on staff from the protected characteristics will be addressed through equality analysis for elderly persons home closures or through EIAs completed for other services being reviewed.

3.2 How could the policy be changed to remove the impact?

Which options have been considered? What option has been chosen?

Any adverse impact would be mitigated or removed by: 

1. replacing the elderly persons home with extra care schemes which aim to provide a better quality of life
2. providing choice to individuals currently in elderly persons home for the type of accommodation that they prefer including right of return or access to the extra care housing
3. working with each individual to take account of their personal needs and wishes, including those relating to cultural requirements, in line with the Closure of a Residential Home procedure
4. providing the option of extra care housing to a larger and possibly wider group of people than previously available
5. ensuring that accommodation and care sourced from the independent sector are of good quality via procurement, contracting, monitoring and quality assurance processes

We acknowledge that there will be some concern, particularly amongst relatives, about the impact of moving on elderly and frail people. The closure of a residential home procedure is in place to manage this transition carefully and sensitively to the highest standards. It is also the case that some people in residential care would have been required at some point to move to a facility that provides nursing care, which our elderly persons homes do not provide. People moving extra care housing are able to stay in this accommodation for longer than might have been the case in traditional residential care.

The condition of our existing elderly persons homes does not meet current standards and they are not the style of accommodation in which people wish to live. Even if we invested in the required maintenance work to these buildings, they would not be sustainable in the medium to long term.

Other local authorities in the same position have chosen to close their homes without replacement, however we have made the decision that this is not the direction they wish to take, and this programme provides a replacement to which people in the elderly persons home being closed have a legal right to return or right to access.

Where there are potential wider service changes (e.g. domiciliary care, day care, night service, respite care) each of these respective service areas will be undertaking equality analysis to establish the impact of the proposed changes and reference needs to be made to these as part of the programme delivery of extra care housing.

In addition, if the proposal to provide 30 extra care schemes is agreed and the eligibility criteria widened, there would be a positive impact on older people and other, younger people who would benefit from this type of housing with care provision.

3.3 Can any adverse impact be justified?

If the adverse impact will remain, can this be justified in relation to the wider aims of the policy or on the grounds of promoting equality of opportunity for one target group?

Information available in section 3.2.

Please seek legal advice on whether this can be justified.

3.4 Are you planning to consult people on the outcome of this impact assessment?

Yes – through existing consultation and communication strategies as well as any strategies developed as part of the reviewing of services process.

When and how will you do this? How will you incorporate your findings into the policy?

Any changes to other services will incorporate consultation with the service users to establish how they would wish future services to be delivered and what other options would be available to them.

3.5 How does the service/policy promote equality of opportunity and outcome?

At present extra care housing is primarily focussed on accommodation for older people. However our future vision is to give all vulnerable adults the opportunity to access extra care housing.

Does the new/revised policy/service improve access to services? Are resources focused on addressing differences in outcomes?

A need has been identified through the mapping process for accommodation for other groups of people with protected characteristics. It will also ensure that we have an equitable extra care housing service across the whole county, giving North Yorkshire citizens more choice on housing options.

Where service delivery changes are proposed, people using the services will have more choice about how their services are delivered and a wider choice of service providers.

Services are monitored through a quality assessment framework which includes fair access criteria and providers are accountable for the services they provide.

Action plan

What are you trying to change (outcome)?	Action	Officer responsible	Deadline	Other plans this action is referenced in (e.g. Service Performance Plan, work plan)	Performance monitoring
Us withdrawing from providing its own residential care home services. Will impact on choices for residential care home placements for older people in North Yorkshire. Particularly in rural areas where private provision is limited.	Residents currently living in elderly persons home will be offered right to access/ right to return to extra care housing developments.	Extra care housing Team	Ongoing	Ongoing – Residents of Lower Greenfoot, Settle – secured right to return to new scheme when built – also in process of securing right to return for residents at Cherry Garth to new scheme when built
	People being assessed as requiring residential care will be informed of the option of extra care housing.	CSM/Team Managers	Ongoing	Ongoing through regular updates to customer service centre and on a localised basis as schemes develop in each area, through local project groups
	Use of the brokerage services, to identify placements for residential care within the private sector.	Brokerage Services	Ongoing	Ongoing on a localised basis when required – i.e. replacement of an elderly persons home identified.
	Completion of domiciliary care review to establish alternative methods / providers of delivering care services to people, enabling them to live in their own homes for longer.	Review project Team	March 2012	Completed March 2012
	Encourage North Yorkshire residents to seek advice and support on care, support and housing options earlier so that they are aware of their options and can be supported to maintain their independence for longer – sign off and production of information booklet (Information about housing, support and care services)	Extra care housing Team	Ongoing End July 2011	Not completed – status unknown
Through service level agreements and QAF’s providers of services to become more accountable.	Completion and introduction of service level agreements and QAF’s	Review Project Team		In progress Aug 2012
Eligibility criteria to access extra care housing – all vulnerable people have the option of accessing extra care housing.	Partners adopting our design and ethos guide changing eligibility criteria.	Extra care housing Team/Housing Partner	Through procurement process	In progress Aug 2012
Encourage people from all protected characterises to access housing and support services through extra care housing, by engaging with them and ensuring that extra care housing options support their needs.	Utilising existing groups/forums to discuss options/proposals/services with them. Providing extra care housing units specifically designed for people living with dementia.	Extra care housing Team/Housing Partner Extra care housing Team/Housing Partner	Ongoing Through procurement process	In progress Aug 2012
	Changes to eligibility criteria to allow all vulnerable people to access extra care housing.	Extra care housing Team/Housing Partner	Through procurement process	In progress Aug 2012
	Ensuring that services meets the specific needs of people living in extra care housing and encouraging the use of community facilities and services to help support those needs.	Extra care housing Team/Housing Partner	Through procurement process	In progress Aug 2012
	Information provided in a variety of formats.	North Yorkshire County Council	Ongoing	ongoing
The perceived perception that residential care is the only option to people with care needs.	Use of existing mechanisms to inform people.	Extra care housing team CSM/ Team Managers	Ongoing	Ongoing through project steering groups –meetings with residents and relatives where a replacement for elderly persons home has been identified.
	Utilising existing groups/forums to discuss options/proposals with them.	Extra care housing team	Ongoing	As above
	Community consultation and information events.	Extra care housing team	Ongoing through procurement process	Attending community events as required i.e. Thirsk, Pickering, Settle
	Information provided in a variety of formats.	North Yorkshire County Council	Ongoing	ongoing
	Consultation and communication with existing residents and relatives.	Extra care housing team	Ongoing through procurement closedown process	Ongoing through project steering groups –meetings with residents and relatives where a replacement for elderly persons home has been identified.
Evaluate the impact on staff from protected characteristics	Include the impact on staff in the EIA relevant to the elderly persons home that is closing.	Extra care housing team	Through closedown process.	Ongoing through HR process where a replacement for an elderly persons home has been identified i.e. Settle