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Stage 1: Equality Impact Assessment
1. What are the main aims purpose and outcomes of the policy change and how do these fit with the wider aims of the organization?
The Council receives an annual grant from the Department of Work and Pensions to provide additional financial help to households in receipt of Housing Benefit or receiving the housing costs element of Universal Credit.
Additional short to medium term financial help is then made available via the Council’s Discretionary Housing Payments (DHP) scheme which is targeted at households affected by welfare reform or are homeless or at risk of homelessness.
The policy was adopted in 2017 to make clear the Council’s approach and priorities for DHP awards. It was developed in collaboration with the multi - agency welfare reform group that it hosts, with representation from voluntary sector, social landlords, Job Centre Plus, Kent County Council and MBC housing team. The policy seeks to help address underlying issues which includes the following:
• Help alleviate poverty
• Encourage employment
• Prevent homelessness
• Support vulnerable households
• Provide support at a time of crisis
The Policy reflects the Council’s strategic vision and will also help achieve the strategic action ‘a home for everyone’ as set out in the Strategic Plan.
The Policy has been updated to provide clarity that:
· a DHP payment is a short term emergency fund
· applications will only be accepted from a person within the Council’s area
· provides a framework for officers to be guided in decision making whilst ensuring consistent treatment but allowing for sufficient discretion
· applications can be received by someone acting on behalf of someone else who is vulnerable or needs support
· the customer is expected to take responsibility such as taking tenancies at reasonable rents, seeks/receives appropriate housing advice, provides sufficient proof of debts/expenditure, shows evidence of job seeking activities (where not vulnerable)
· that the DHP policy will be reviewed annually in future.
2. How do these aims affect our duty to:
• Eliminate unlawful discrimination, harassment and victimization and other conduct prohibited by the act.
• Advance equality of opportunity between people who share a protected characteristic and those who do not.
• Foster good relations between people who share a protected characteristic and those who do not.
The revisions to Housing Benefit under the Welfare Reform Act 2012 offered a number of protections to those with protected characteristics including those with a disability and the elderly, to prevent inequality.
The DHP scheme is open to all Housing Benefit claimants, making no distinction between those with protected characteristics and those without. It is therefore non-discriminative in its aims.
DHP advances equality of opportunity for both claimants who share a
protected characteristic and those who do not.
The policy should contribute to fostering good relations with people with protected characteristics and those who do not, who access our services.
3. What aspects of the service change including how it is delivered or accessed could contribute to inequality?
The DHP policy continues to provide clarity on the approach the Council takes with DHP awards.
The scheme itself is flexible and covers a range of housing costs or scenarios. The scenarios listed in the policy are not exhaustive but demonstrate numerous changes in housing circumstances which could affect those with protected characteristics and those without.
The policy is intended for departments and external agencies providing financial/housing advice.
The availability of DHP is promoted through customer service, housing staff, registered social landlords, private sector landlords and local advice agencies. It will also be promoted when the council notifies individuals on their Housing Benefit entitlement or when communicating any change or restriction in Housing Benefit awards and through the information made available online and at customer access points.
Claims for DHP are generally made in writing. If the customer would rather discuss their circumstances in person or they are unable to complete a form a private interview will be arranged.
4. Will the policy have an impact (positive or negative) upon the lives of people, including particular communities and groups who have protected characteristics ? What evidence do you have for this?
The policy makes the Council’s approach clear for DHP awards.
When the Policy was developed Census 2011 population data and DHP claimant data used to ensure it was reflective and representative of Maidstone’s population and those who were most vulnerable.
The revised policy is intended to be more accessible, consistent and
transparent and will be kept under annual review to ensure it is reflective of