Council Tax Relief. Brentwood Borough Councils local council tax support scheme. An equality impact assessment

Transcription

1 Council Tax Relief Brentwood Borough Councils local council tax support scheme An equality impact assessment

2 This Equality Impact Assessment is based on the financial models adopted for consultation by Brentwood Borough Council. An Impact Assessment of the change to local support for Council Tax nationwide is here A further Equalities Impact Assessment of the final scheme will be produced as will one for the Pan Essex framework which is a common framework of rules to replace the national regulations that local authorities across Essex have worked on. This document forms a key part of our consultation process. Proposed change From 31 March 2013 Council Tax Benefit has been abolished. The Local Government Finance Bill proposes to replace Council Tax Benefit with a scheme designed by each local authority. Funding will no longer be demand led. It will be based on an estimate of Borough caseloads, with an overall budget 10% lower than that of Council Tax Benefit. Reason for the service change The Council Tax Benefit scheme was abolished by the Welfare Reform Bill 2011 and the Local Government Finance Act will be amended-section 13A allows for the development of a new Localised Council Tax support scheme to be implemented from 1 April Every billing authority in England must design a scheme specifying the reductions which are to apply to amounts of council tax payable in respect of dwellings in its area. Currently Council Tax benefit is a national scheme to assist those who are on a low income and have to pay Council Tax. Individuals apply for Council Tax Benefit and if their income is below a certain level they are eligible for a reduction on their Council Tax bill. The council receives a grant to pay for this. The Government has announced that expenditure on the scheme must be reduced by 10% from 1st April 2013 and it will be for Local Councils to determine how to manage that funding reduction. It is important to note that DCLG are basing the reduction of 10% on Office of Budget Responsibility (OBR) estimates of caseload for 2013/14. Their consultation document is here The OBR have assumed a reduction in the level of caseload in Brentwood. Taking this reduction into account funding totals for residents in Brentwood will be reduced by 16.1%. How we arrive at the 16.1% figure is detailed at the end of this document. 2 Localised Support for Council Tax. Equality Impact Assessment Brentwood Borough Council

3 There are strict guidelines from the Government to ensure support for pensioners will be delivered through a national framework of criteria and allowances. Their awards will be calculated on the same basis as now. Brentwood Borough Council will need to design a new support policy. The scheme must be in place by 31st January 2013 or the Government default scheme modelled on current Council Tax Benefit scheme will be imposed. The default scheme will by design, not meet the shortfall in funding. This would mean that the Borough and its preceptors would have to find the shortfall from elsewhere. Information about the changes The Department for Communities and Local Government (DCLG) have completed an Impact Assessment for the implementation of local support for Council Tax nationwide; xsupport Brentwood Borough Council have the option of allowing the cost of the shortfall to fall on the General fund and the preceptors in the collection fund or or designing a revised scheme which incentivises work. Financial Impact Our proposals would affect current claimants as follows Case Group A B C D Pension Age Working Age Passported Working Age Vulnerable Working Age Other Totals Number of claims Average weekly award No. of claims adjustment for pension age change Total weekly Benefit 39, , , , Average WEEKLY LSCT Total annual awards 2,069, ,478, , , ,257, Total annual CTS Awards 2,069, ,109, , , ,666, This does not take into account any reductions in awards for claimants aged under Localised Support for Council Tax. Equality Impact Assessment Brentwood Borough Council

4 Examples of the changes will be made available online and a tool will be available that will allow claimants to model how the changes affect them personally. This will form part of the consultation process. Options 1. Do nothing Accept the Government default scheme (and incur the costs of this scheme ) Find the 10% reduction in funding through reduction in spending in other areas Use technical amendments to Council Tax to offset part of the savings required. The County have made clear that they will not support a scheme that passes the cost of a decision to make no change on to them. There is a requirement in the Local Government Finance Bill for the billing authority to consult their preceptors. Essex County Council, Police and Fire have all been kept informed about the design of the scheme and they have made clear that the scheme should be cost neutral, which means that the reductions must be found by reducing the level of support to benefit claimants. By taking a decision to adopt a scheme broadly similar to the default scheme, the Council could find itself with a legal challenge from the precepting authorities. An option would be for Brentwood Borough Council to meet the cost of the shortfall entirely and use its general fund to subsidise the collection fund. A 720,000 shortfall would be beyond the resources of Brentwood Borough Council and would dam. 2. Design an alternative scheme The preferred option would be to continue a means tested scheme aimed at helping those with greatest need. This would continue to be a means tested scheme built on the framework of the existing Council Tax Benefit with modifications to make the scheme affordable. The proposals being consulted on are 1) Reduce Capital Limit from 16,000 to 6,000. 2) Restrict entitlement to a maximum of Band D. 3) No support for residents in Band F, G H properties. 4) Everyone pays at least 20% 5) Include Child Benefit/Maintenance in the assessment. Taking these options alone save the Council Tax Scheme 749,000. They do not however do anything to improve work incentives beyond the existing tapers and allowances provided for in the current scheme. To this end the following proposals are also being considered 4 Localised Support for Council Tax. Equality Impact Assessment Brentwood Borough Council

5 6) To work with the social sector rent restrictions, we propose the abolition of nondependant deductions (so there would be no penalty for other adults living in the property). 7) Protection of vulnerable claimants (i.e. not required to pay 20%), defined as in receipt of a veterans agency benefit and those entitled to the severe disability premium. 8) Reduce the in-work taper to 15% for those who satisfy working tax credit eligibility conditions, with support assessed on 100% of their liability and not 80%. 9) Adding in a 13 week protection for anyone who has not claimed Council Tax Support within the last year based on similar rules that exist within Housing Benefit. It should be noted that including the incentives outlined in 6) to 9) above reduces the amount of savings achieved and as such the scheme would no longer be cost neutral. In order to address this, the following is also recommended for consideration: Under 25 s A final option was also considered by the Member Working Group which was to end support for Under 25 s. It was felt by the Group that a blanket clause such as this would not necessarily identify genuine hardship cases. It is therefore proposed that this option be included in the public consultation, but that it will be subject to defined criteria. For example; Under 25 s leaving care will be protected for a 2 year period. Technical Changes Furthermore, there are a number of additional technical changes to Local Council Tax Support and these are in the detailed consultation documents. Prominent among those and important to highlight, will be a change to reflect the way self employed claimants are treated. It is proposed that self employed income will be treated in a similar way as it will be under Universal Credit. This means that for the first year of self employment we will accept that earning potentials are lower but in year two onwards a minimum income floor will be applied. This will mean that we will treat the claimant as earning at least minimum wage. Council Tax Discounts and Exemptions From 1 April 2013, Councils are being given the discretion to change the current levels of discounts and exemptions awarded to certain types of property for Council Tax properties. The key categories affected are: Class A Property Under Structural Renovation Class C Unoccupied Property Class L Mortgagees in Possession The current arrangements for these properties are as follows: Class A exempt for up to 12 months, followed by full charge. Class C exempt for up to 6 months, followed by full charge. Class L full exemption from the date the mortgagee takes possession (until such time as the property is re-sold). The following changes are proposed: Class A exempt for up to 6 months, followed by full charge. Class C exempt for up to 3 months, followed by full charge. 5 Localised Support for Council Tax. Equality Impact Assessment Brentwood Borough Council

6 Class L no exemption applies from the date the mortgagee takes possession. For Class A, it is felt that the 6 month period will allow a reasonable time period in order to undertake any structural and/or renovation work required. For Class C, it is felt that the 3 month period will allow for any short void periods between tenancy/owner change over, without discouraging owners and landlords to provide the necessary up to date information. A separate equalities impact assessment will be prepared for the technical changes to Council Tax as they form a secondary part of the Council Tax Support scheme. Stakeholder involvement Following publication of the draft scheme, a formal consultation period will run between 14 August 2012 and 22 October This is a 10 week consultation period to reflect the complex nature of the proposals and the short timetable the borough faces for implementation. A period of 12 weeks was considered, however the timetable does not allow for this due to the need to fit in with the budget setting process. To mitigate the shorter consultation period the Council is committed to reaching out to minorities, the disabled and other affected groups. The Leader of the Council will hold open public meetings and meetings will be held across the Borough. The Council will direct mail all current Council Tax Benefit claimants of working age with details of the proposed scheme. General awareness will be raised via press releases and a series of outreach events run. An online questionnaire and draft scheme will be available on our website. Paper versions of the questionnaire will be sent to all claimants. Resources will be applied so that paper answers can be included in the on-line consultation. We will also run three targeted technical consultations. These will deal with the impact of LCTS on Parish Councils, changes to self employed income and the design of the hardship fund. The Council has already worked with the local Citizens Advice Bureaux, through an officers working group. The results from the Working Group will be fed in to the main consultation at the Policy Committee. Brentwood Borough Council has also had a call for evidence page on localised support Council Tax on the website since January This link has been on the Brentwood home page and it links to it are included on welfare reform pages. One member of the public responded. 6 Localised Support for Council Tax. Equality Impact Assessment Brentwood Borough Council

7 Impact of change- Who will be affected. How the change will impact on equality groups? Any positive and negatives impacts of the changes on users. Actions taken to avoid or lessen any negative impacts. The scheme has been designed to improve work incentives. Brentwood Borough Council has designed their scheme so that restrictions on benefit can be mitigated by the claimant, either through finding employment or moving to a cheaper property. The primary groups targeted by the reductions are those of working age because the Government is legislating to protect those of pension age from the reductions. Analysis Financial impact on services of not reducing support levels Brentwood Borough Council Council Tax Payers Positive Brentwood Borough Council believes that the growth in expenditure on Council Tax support from 2006/07 is unsustainable from an economic perspective. The Council therefore welcomes the opportunity to reform Council Tax support in a way that reflects the needs and priorities of the taxpayer. This Council is committed to delivering a quality service to our residents, mindful of the need to reduce government expenditure in order to reduce the Government s budget deficit. Negative Our Precepting Authorities, who we must consult in the design of the scheme have made it clear that they want a cost neutral scheme. This means that they want the level of support provided to those in need limited to the level of grant that will be provided. A formal decision to retain current levels of support could result in a challenge from our preceptors. It is highly likely that Brentwood Borough Council would then become liable for the whole 720,000 shortfall. To fund this shortfall the Borough would need to look towards reducing services in planning and environmental health. Planning delays would discourage businesses from investing in Brentwood. This would increase the level of support we would need to pay. Reductions in environmental health could harm our night time environment that Brentwood is justifiably proud of, impacting on our economy still further. 7 Localised Support for Council Tax. Equality Impact Assessment Brentwood Borough Council

8 This scheme is designed so that those affected by reductions in support levels can mitigate that reduction by either finding employment or moving to a cheaper property. Age Positive Negative Pension Age claimants The DCLG equality impact assessment applies. Pensioners will have their claims assessed as now. Due to the block-grant nature of local support for Council Tax, campaigns to encourage take up of entitlement for this group Working Age claimants Abolition of Non- Dependant deductions. In the current Housing and Council Tax Benefit schemes, non dependant deductions are used to reduce the maximum award payable. For Council Tax Benefit, the highest deduction is currently This is the expected contribution from the other adult living in the home. From April 2013 Housing Benefit will change. Penalties of up to 25% of the maximum rent will be introduced for social sector tenants who have a home larger than their needs. If the Borough chose to retain nondependant deductions (or increase them), social sector tenants could therefore be penalised for allowing their family to stay together or for allowing them to move out. This policy benefits most those non-dependants whose gross income is 394 a week or above. See the table of nondependant deductions for will end. Reduction in capital limit from 16,000 to 6,000. It is accepted that as a result of this change, at least in the short term, there could be a difference in the treatment of those on a passported benefit and those who are not receiving a passported benefit. While there is a different treatment for those on passported benefits, their income is reduced to reflect capital over 6,000, through tariff income calculations. It will be administratively prohibitive to re-verify the circumstances of all of those on passported benefits. It is also unusual for someone on a passported benefit to have in excess of 6,000 especially as the limit was only recently raised from 8,000. Nor is this a situation that will continue over the operation of localised council tax support as passported benefits will come to a gradual end starting in October Restrict entitlement to a maximum of Band D and removal of support from people in Bands F, G and H As a result of Housing Benefit changes, restricting private 8 Localised Support for Council Tax. Equality Impact Assessment Brentwood Borough Council

9 details. ocs/a pdf Protection of vulnerable claimants (i.e. not required to pay 20%), defined as those entitled to the severe disability premium The reductions in support are designed to affect only those who could not increase their income through work. The Government has recognised that pensioners should not be expected to find work to increase their income. The Council has decided that those who are severely disabled should also not be expected to find work. This will be defined as meeting the qualifying conditions for the severe disability premium. Veterans Benefits The Council also wants to continue to recognise and support those who have served in our military and who as a result of that service have been widowed or disabled. Brentwood Borough Council currently ignores war disablement and war widows pensions in full for Housing and Council Tax Benefit purposes. We propose that veteran s agency incomes are ignored as part of the sector claimants to the bottom 30% of the rental market, the majority of residents in receipt of Council Tax Benefit in higher bands are owner occupiers. This group is generally cash poor and equity rich. By continuing to support this situation, the Council would therefore be funding people who could significantly improve their financial circumstances by downsizing. We propose that a support fund will be created to assist those who have been placed by the council in larger properties. Everyone pays at least 20% The other reductions in support have reduced the level of expected contribution from claimants. Without the other options the Borough would have had to look at a minimum 30% contribution in order to meet the reduction in budget of 16.1%. In addition, adding in protections for those who have recently lost their job and those who are severely disabled or on a veterans agency pension limits this contribution to people who could improve their situation by gaining employment. Their circumstances of the claimant can be significantly improved through work, as the scheme is designed that those who would qualify for working tax credits (or the equivalent in work element of universal credit) will have their claim assessed on 9 Localised Support for Council Tax. Equality Impact Assessment Brentwood Borough Council

10 assessment of localised support for Council Tax and that their award is based on 100% of liability. Reduce the in-work taper to 15% for those working more than 24 hours per week, with support assessed on 100% liability and not 80%. Any localised support scheme must provide for incentives to work. To improve work incentives the Borough could have looked at areas such as earned income disregards (the amount of wages ignored by benefits before it is included in the assessment) however such an approach would have meant that the Council would have to demonstrate how we arrived at new figures, therefore the Borough decided to retain all existing premiums and disregards as is. These will be uprated in line with HB disregards. The Borough does not have an economic model that would enable it to model the cost of starting employment. As an alternative Brentwood is proposing that those who work more than 24 hours per week should have their benefit award assessed on 100% of their liability (subject to the Band D limitations) and a 15% taper. This 100% of their liability. A hardship fund will be established to assist those who are unable to pay the 20% contribution. This will reduce the risk of it impacting upon those truly unable to pay. Include Child Benefit and Maintenance in the assessment. Child Benefit and Child Maintenance were included in Housing and Council Tax Benefit until The decision of the government to disregard these benefitted those with higher levels of income as it brought them back into benefit entitlement. Particular groups may feel this is unfair due to large families being a cultural factor. This can be related to religious beliefs and would affect the families disposable income. The greatest impact may be on lone parents. ntent.aspx?categoryid=365 We would restore a 15 disregard for child maintenance, with any additional income used in the calculation. The impact of this change would therefore be on those with high levels of child maintenance awarded. We would only take it into account where it is being paid. In general, as this group have a higher level of income they are 10 Localised Support for Council Tax. Equality Impact Assessment Brentwood Borough Council

11 provides a guarantee that a claimant will always be better off in work. 13 week protection To mirror a similar protection in Housing Benefit, where the Council is satisfied that the claimant or a linked person was able to meet the financial commitments for his dwelling when they were entered into and provided they were liable for council tax at that address for at least a year, there shall be no restriction applied during the first 13 weeks of the claimant's award of Council Tax Support. This means for the first 13 weeks of the assessment, the claim will be based on the full liability (including those above Band D). This shall not apply where a claimant or the claimant's partner was previously entitled to benefit in respect of an award of council tax benefit or local support for Council tax which fell wholly or partly less than 52 weeks before the commencement of the claimant's current award of council tax support. This policy is designed to reward those who have contributed to the system by affording them a greater level of protection than those that have not. better able to pay a contribution towards their council tax. Technical Changes to the treatment of self employed income. Some self-employed people under the existing Housing and Council Tax Benefit schemes report very low levels of income. Often the businesses have been declaring no or little income for a number of years. As this scheme is a localised scheme, paid via Council Tax, and as there will be reductions to support for people who are vulnerable we are looking to change this. This scheme recognises that it can take some time before a business becomes profitable. Once the business is established it would be reasonable to expect to those who are self employed to enjoy an income from their business activity that is at least as high as someone employed in a low paid job. So for the Brentwood support scheme we are considering introducing a floor of assumed income from selfemployment, to be operational from at least the second year of any claim for support (including within year one of the localised scheme previous awards of Council Tax Benefit). The floor will be set at the National Minimum wage for the reported hours. This assessment cannot be applied 11 Localised Support for Council Tax. Equality Impact Assessment Brentwood Borough Council

12 to Housing Benefit. Therefore this will only be implemented if our IT system allows for different treatment for HB and CTS. The reason for this is the Borough would not wish to have different methods of assessing income for self employment for those claiming or not claiming Housing Benefit. This change would affect working age self employed people who have been claiming Council Tax Benefit and then Council Tax support as a self employed claimant. New self employed claimants of Council Tax Relief would only be affected in the second year of any award. Exclusion of Under 25 s At a time when their earning potential is at their lowest, employment should not be discouraged by high housing costs. This group generally has the ability to be more mobile with regards to employment and housing than older groups. Private Sector Housing Benefit rules already limit single people of this age group (now under 35 s) to the maximum level of a room in a shared house. Single claimants in these circumstances should generally not be liable for Council Tax, if their tenancy reflects that of a home in multiple occupation. As the Housing Benefit system provides for disincentives for single people to live in unshared properties it would be realistic for Council Tax support to reflect this. Modelled financially was the complete exclusion of all claimants under 25. Councillors want to seek further opinions on this. Should this policy apply to couples and if so should this apply to the younger of the couple or the older? Should the disabled be exempt? What kind of disability? 12 Localised Support for Council Tax. Equality Impact Assessment Brentwood Borough Council

13 Defined by existing premia (severe disability?) As it stands at the moment, new claimants under 25 would be protected from restriction if they met the conditions for the 13 week protection. As caseload data is continually changing analysis and effects will continue throughout the consultation period As at 5 August 2012 there were a total of 32,286 properties liable for Council Tax in Brentwood of those are currently receiving Council Tax Benefit, of these, around 2000 working age households would receive less support towards their Council Tax Bill To minimise the cost of collection and the impact on the very poorest, who would find themselves unable to increase their income, proposals affect those who are able to better their position. The changes being considered affect Working Age only. The DCLG will govern the scheme for those of pension age, although no additional funding will be available if demand increases. Disability Positive Negative Higher allowances will continue to be awarded in the calculation of support for those receiving disability benefits. The removal of nondependant deductions will provide those with the disability premium the same protection afforded to those with the severe disability premium under the current Council Tax Benefit scheme. Our proposal allows for a non-dependant to stay and provide help where necessary without any deduction. The disabled and vulnerable are on average better off as a result of Council Tax relief. A disability friendly version Those who are getting the disability premium and not the severe disability premium may pay more if they have no non-dependant deductions. Examples will be provided online as part of the consultation. 13 Localised Support for Council Tax. Equality Impact Assessment Brentwood Borough Council

14 of the consultation will be made available online and sent to those who are claiming and who have a disability or severe disability premium. Household demographics Positive Negative Single person Household. 13 week protection would be available to those who could afford their property. Couple with no children Single people are able to move into work more easily than other demographic groups and then qualify for the lower taper. 13 week protection would be available to those who could afford their property. Couples will benefit from the 10 earned income disregard and the lower taper should they take up work totalling 24 hours. Single people under 25 are likely to be impacted by this change, depending upon consultation results. This is already mitigated by the effect of Housing Benefit restrictions which limit single people to rooms in shared houses. This group is better able to be mobile in the labour and property market. Single claimants under 35 are also restricted under Housing Benefit to the level of benefit payable for a room in a shared house. Most people with these tenancies are not required to pay Council Tax. Older single claimants above the age of 35 are likely to be expected to pay more. Couples under 25 are likely to be impacted by this change, depending upon consultation results. Couples older than 25 will be expected to pay more towards their council tax if they are long term unemployed. Lone Parent Families 13 week protection would be available to those who could afford their property. The hours requirement for Lone parents who are long term unemployed will be expected to pay more. Some working age lone 14 Localised Support for Council Tax. Equality Impact Assessment Brentwood Borough Council

15 Families with children Households with carer the lower taper is reduced for lone parents (16 hours). Lone Parents will benefit from a 25 earned income disregard. The premiums that exist now, which reflect the additional costs of being a lone parent are continuing. Lone Parents, with older children will benefit from the removal of non-dependant reductions. 13 week protection would be available to those who could afford their property. The premiums that exist now, which reflect the additional costs of bringing up a family are continuing. Families with older children will benefit from the removal of non-dependant reductions. Households without a formal carer, but with a nondependant relative who remains in the house to care for a relative will benefit from the removal of nondependant reductions. Carers Premium and the premiums related to disability remain in this scheme. parents may lose out by the inclusion of child benefit and child maintenance in the assessment of support. Lone parents do have a higher needs allowance and the greatest impact will be felt by those with more money. Families who are long term unemployed will be expected to pay more. Some working age parents may lose out by the inclusion of child benefit and child maintenance in the assessment of support. Parents do have a higher needs allowance and the greatest impact will be felt by those with more money. Except where the claimant or partner is severely disabled, these households will pay more, unless they have other adults living with them. 15 Localised Support for Council Tax. Equality Impact Assessment Brentwood Borough Council

16 Race / Ethnicity Positive Negative No CTB data held The scheme will not treat people in these groups any differently. Facilities are available for those for whom spoken or written English is either not available or a second language. Consultation material will be made available in other languages should this be requested. Black and ethnic minority communities often face higher rates of unemployment than other groups. These changes are designed to minimise the impact of the reduction in funding on those who have no ability to increase their earning potential through employment. Gender Positive Negative Neutrality This scheme does not treat men or women differently. The premiums and levels of support are the same regardless of gender. Child Benefit and Child Maintenance were included in Housing and Council Tax Benefit until The decision of the government to disregard these benefitted those with higher levels of income as it brought them back into benefit entitlement. Particular groups may feel this is unfair due to large families being a cultural factor. This can be related to religious beliefs and would affect the families disposable income. The greatest impact may be on lone parents. /content.aspx?categoryid= Localised Support for Council Tax. Equality Impact Assessment Brentwood Borough Council

17 Females Unemployment among women in Brentwood is low (352). Some working age lone parents may lose out by the inclusion of child benefit and child maintenance in the assessment of support. Lone parents do have a higher needs allowance and the greatest impact will be felt by those with more money. Male and Female lone parents are treated the same under this Council Tax support scheme. Males Male unemployment is much higher in Brentwood than female unemployment. However the unemployment rate is relatively low and the Borough is prosperous. Issues and Recommendations The national Council Tax Benefit scheme is to be replaced with a Local Support scheme designed by each of the billing authorities, in this case Brentwood Borough Council. At the same time the Government have announced the funding for the scheme will be cut by 10%, however the indicative grant figures allocated recently would require a cut of 16.1%. The funding calculations are available online as part of the consultation process and the associated evidence. Once the final allocations of the grant are known, actual savings totals may need to be adjusted. The Borough plans to have a direct consultative exercise with those affected once a final scheme is devised. The Government have decided that pensioners must be protected and have regulated the approach in calculating future support for them. Brentwood Borough Council, along with other Essex authorities have consulted with Essex County Council, the Fire and Police as major preceptors and they have been unable to fund the shortfall therefore the support for working age claimants would need to be reduced. Brentwood Borough Council has designed a scheme, which we believe targets the reductions towards those most able to improve their circumstances. 17 Localised Support for Council Tax. Equality Impact Assessment Brentwood Borough Council

18 To protect vulnerable people who may be unable to improve their circumstances, Brentwood Borough Council will create a hardship fund to act as an additional safety net. This would allow for individual circumstances to be taken into account when appropriate. A full evaluation of responses from the consultation will be carried out before the final scheme is agreed From April 2013 the effects of the final scheme will need to be carefully monitored and any negative effects minimised Operation of the Hardship Fund The Borough is aware that a complex relief scheme may exclude people who are unable to improve their circumstances, at least in the short term. The Borough welcomes the prescribed regulations for the local support for Council Tax scheme in full. These regulations will allow for further reductions to be made under S13A(1)c) of the Local Government Finance Act 1992 as substituted by the this Local Government Finance Bill. The Borough will be consulting on the design of a hardship fund. For claimants who face hardship the Borough is seeking views about whether the hardship fund will operate on broadly the same basis as discretionary housing payments (without the requirement to qualify for Council Tax support) or whether it will operate in a similar way to the existing Council Tax Benefit scheme. While views on the design of a hardship fund are welcomed from the wider public, we will actively seek the views of welfare specialists and benefits advice organisations. 18 Localised Support for Council Tax. Equality Impact Assessment Brentwood Borough Council

19 Tables Brentwood Labour Market statistics Source Total JSA claimants (June 2012) Brentwood Brentwood East Great Britain (numbers) (%) (%) (%) All people Males Females Source: ONS claimant count with rates and proportions JSA claimants by age duration (June 2012) Brentwood (level) Brentwood (%) East Great Britain (%) (%) Aged 16 to 64 Total Up to 6 months Over 6 and up to 12 months over 12 months Aged 18 to 24 Total Up to 6 months Over 6 and up to 12 months over 12 months Aged 25 to 49 Total Up to 6 months Over 6 and up to 12 months over 12 months Localised Support for Council Tax. Equality Impact Assessment Brentwood Borough Council

20 Aged 50 to 64 Total Up to 6 months Over 6 and up to 12 months over 12 months Source: ONS claimant count - age duration with proportions Note: % is number of persons claiming JSA as a proportion of resident population of the same age Working-age client group - key benefit claimants (November 2011) Brentwood Brentwood East Great Britain (numbers) (%) (%) (%) Total claimants 3, By statistical group Job seekers ESA and incapacity benefits 1, Lone parents Carers Others on income related benefits Disabled Bereaved Key out-of-work benefits 3, Source: DWP benefit claimants - working age client group Key out-of-work benefits includes the groups: job seekers, ESA and incapacity benefits, lone parents and others on income related benefits. Note: % is a proportion of resident population of area aged Localised Support for Council Tax. Equality Impact Assessment Brentwood Borough Council

21 Caseload trends Over recent months our caseload has been falling. Although it is still well above recession levels. Total caseload Jan Apr Jul Oct Jan Apr Jul Oct Jan Apr Jul Oct Jan APR May JUN AUG Localised Support for Council Tax. Equality Impact Assessment Brentwood Borough Council

22 Impact Assessment Results The final options for the scheme will be tested during consultation and subsequently evaluated against the following framework from the Equality and Human Rights Commission s guidance on Making Fair Financial Decisions : Outcome 1: No major change required when the assessment has not identified any potential for discrimination or adverse impact and all opportunities to advance equality have been taken. Outcome 2: Adjustments to remove barriers identified by the assessment or to better advance equality. The Council will need to be satisfied that the proposed adjustments will remove barriers. Outcome 3: Continue despite having identified some potential for adverse impacts or missed opportunities to advance equality. In this case, the justification will be included in the assessment and will be in line with the duty to have due regard. This will include sufficient detail on how the impacts are being reduced and how this will be monitored. Outcome 4: Stop and rethink. This is unlikely, but will be the measure taken if unlawfully disproportionate actions are found. The Equality Impact Assessment, completed above, is based on a thorough desktop analysis of the impacts based on the current demographics of current benefit claimants. However, in order to ensure a through and comprehensive analysis of the potential impacts of developing a localised council tax support scheme the Council will conduct a 10 week period of consultation. The scheduled 10 week consultation will allow Brentwood Borough Council to test the impacts forecasted in this assessment and we will work with the community to put in place tangible mitigations. Questions posed by stakeholders will be noted and where appropriate the answers will be integrated into the final draft of this scheme. A broad ranging consultation will be undertaken which will include this document and:- Promotion of our online survey to benefit claimants and non benefit claimants. Inviting expert stakeholders to consult and advise on the proposed scheme. Consultation workshops We will work with representatives from across the community and voluntary sector in Brentwood and they will be given the option of consulting their resident networks on the proposals and feeding this back to the council. Feedback from the consultation will be presented to a Cross Party Member Working Group and an Officers Working Group will work on any administrative issues that arise. A shortened but directly targeted consultation exercise with affected claimants will run in December. In January, the Policy Committee will assess the impact of that consultation. A special meeting of the Council will decide on the final scheme by 31 st January Localised Support for Council Tax. Equality Impact Assessment Brentwood Borough Council

23 In addition to this the Council recognises its continuing duty to carry on monitoring the effects of any decision taken following on from to initial consultation process and this will be carried out through a robust process. The details of the monitoring of real impact will be published later but will include close monitoring of the financial hardship on vulnerable groups. 23 Localised Support for Council Tax. Equality Impact Assessment Brentwood Borough Council

24 Alternative options considered by the Council and the financial model are listed here: Details of the technical consultations are also available online at 24 Localised Support for Council Tax. Equality Impact Assessment Brentwood Borough Council

25 Comments on this consultation document should be sent to Local Support for Council Tax Consultation Brentwood Borough Council Town Hall, Ingrave Road, Brentwood, Essex CM15 8AY Web address: Large print copies of this document can be requested 25 Localised Support for Council Tax. Equality Impact Assessment Brentwood Borough Council