Scotland – The Intermediate Priorities Plan (IPP) – Dr Addy's – Scottish Anti-Racism Resource Library (ARRL)

Scotland – The Intermediate Priorities Plan (IPP)

The Immediate Priorities Plan (IPP) is based on delivering on the recommendations of the Expert Reference Group (ERG) on COVID-19 and Ethnicity. The IPP focuses on supporting communities to recover from COVID-19 while implementing the recommendations of the Expert Reference Group on COVID-19 and Ethnicity (ERG). As such, there is a need to ensure there is an ongoing focus on implementing the REF that may have been lost through pivoting to responding to the pandemic. A significant proportion of the ERG recommendations focus on systemic and structural change. A key recommendation of the ERG was to establish an external body to provide a range of functions, including oversight and governance. Recommendation 7 was to set up external governance to review race equality work, and the formation of an observatory

IPP Recommendations – Systemic Issues and Risk

COVID-19 Immediate Action

1. Emergency Sustenance Fund Payment

2. No Recourse to Public Funds

3. Test and Protect and future health measures

4. Fair work practices

5. Investment in Minority Ethnic Organisations and mental health services

6. Public Health Messaging

Short-term actions

7. Accountability – Independent Oversight Commission

8. Functions

9. Anti-Racism Actions

10. Corporate Accountability

11. National Performance Framework

12. A Measure of Racism

13. Housing and Overcrowding

14. Recovery and Remobilisation Plans, Investment Fund and Reporting

15. Employment

Changing the Cultural Landscape

16. Change the Curriculum for Excellence

17. National Museum and Statues

Improving ethnicity coding through improved data infrastructure

1. Make ethnicity a mandatory field for health databases

2. Linkage to census

3. Develop a CHI field

4. Ethnic Group populations

5. Social care data

6. Flexibility in data collection

Improving ethnicity data collection at source

7. Co-ordinated Action

8. Primary Care Health Ethnicity Data Collection

9. Participation by Minority Ethnic People and Communities

Improving Workforce Data

10. Monitoring workforce data

11. NHS Workforce Data

12. Social Care Workforce Data

Reporting, Accountability and Governance

13. Reporting data by ethnicity

14. Reporting data by ethnicity

IPP Recommendation Summary – Systemic Issues and Risk (SIR)

IPP Summary – Systemic Issues and Risk (SIR)

Link	Description
IPP – SIR 01: COVID-19 Immediate Action – Emergency Substenance Fund Payment	The Scottish Government should deliver an emergency sustenance fund using the existing infrastructure of state support for people and families across Scotland. This may involve using the Scottish benefits system creatively. The Scottish Government should ensure that any future COVID-19 response includes the learning and needs identified through the current programme.
IPP – SIR 02: COVID-19 Immediate Action – No Recourse to Public Funds	The Scottish Government should review the nature of the No Recourse to Public Fund restrictions and determine a localised strategy within those restrictions which can navigate how they can be overcome. Currently, the gaps in statutory service provision are patched up by the voluntary sector and volunteers. This cannot continue given the consequences of COVID-19, destitution and poor health.
IPP – SIR 03: COVID-19 Immediate Action – Test and Protect and Future Health Measures	a) There must be Minority Ethnic participation at all levels of the COVID response. It is also important to ensure that communication with individuals from minority ethnic communities by Test and Protect teams is effective and that Test and Protect teams have incorporated processes and expertise which reflect the diversity of the communities they serve and the intersectional framing of their experiences. b) Scottish Government must ensure that the needs of minority ethnic communities are considered and acted upon. There is a risk of undermining the broader zero COVID-19 community transmission approach if this is not done. c) Culturally competent health promotion and disease prevention programmes, relating to issues such as the higher risk of diabetes and Cardio-Vascular Disease among South Asians, is well known but efforts to tackle it may have diminished recently and it is important that such efforts are reinvigorated. Further, the Independent Race Equality Framework Advisor had previously made a recommendation involving funding the implementation of a low cost community intervention project with the aim of bringing about lifestyle changes that would a) prevent and b) improve management, of these diseases.
IPP – SIR 04: COVID-19 Immediate Action – Fair Work Practices	The Scottish Government, NHS Scotland and other partners must demonstrate how they will ensure that fair work practices are in place in health and social care settings, particularly in relation to PPE, and other workplaces.
IPP – SIR 05: COVID-19 Immediate Action – Investment in Minority Ethnic Organisations and Hental Health Services	a)In the event of enhanced lockdown, the Scottish Government will need to invest in NHS Scotland Mental Health provision. b) Further, there should be support for minority ethnic led sector organisations to provide the service required to Scotland’s diverse demographics. c) In addition, the Scottish Government and NHS Scotland should deploy culturally competent and multi-lingual psychotherapists and counsellors as there are ethnic inequalities in accessing mental health services. d) More broadly, the Scottish Government should commission research to identify barriers and put in place a plan to address the unmet need and persistent ethnic inequalities in mental health care.
IPP – SIR 06: COVID-19 Immediate Action – Public Health Messaging	a) The Scottish Government must take action to ensure the inclusivity of public health messaging around COVID-19 minority ethnic communities and migrants. This should take into account language barriers, literacy levels, cultural factors, religious beliefs and differential access to health-related information among diverse communities. Translation is necessary, but not sufficient. Co-production and pre-testing of messaging with communities is essential for tailoring to specific cultural contexts. b) Local authorities need to have appropriately experienced staff or access to sources of advice so they can actively engage with ethnic communities to understand local issues and act as trusted sources of communication with the community. Messages should be tailored to reflect local realities and consider cultural norms, accessibility of services, and financial disadvantage. c) Messaging and engagement needs to understand that groups are not homogenous. d) Work needs done at a local level – it is essential to work with trusted 3rd parties in the relevant communities.” There is concern that public communication around the higher proportion of cases in minority ethnic communities’ could risk creating a blame-game that would lead to negative repercussions for these groups e) The Scottish Government should be clear and resolute in standing up to this danger,
IPP – SIR 07: Short-Term Actions – Accountability – Independent Oversight Commission	a) A key recommendation is to establish a more effective accountability and governance infrastructure in Scotland. b) The proposal is that a new infrastructure, building on what exists already, should embed four elements (1) An Observatory which brings together quantitative and qualitative data on ethnic and racial inequalities in Scotland. This should not only include epidemiological data but also cultural, historical and other socio political and economic factors. (2) A repository which holds historical and current evidence from arrange of different sources to maintain awareness and inform actions. (3) Collaboration that reflects the consensus between the Scottish Government and all other relevant stakeholders that Scotland needs to better engage with the experiences of those racialised in society. (4) Co-production processes led by those who are most affected by its outcomes. c) It is important that there is independent external oversight of the work and linked to work that is being taken forward elsewhere in Scotland. An independent Oversight Commission must be put in place consisting of representatives from minority ethnic communities, academia, third sector and other national and international experts. The Oversight Commission should provide strategic oversight to the progression of the recommendations made by the Group and also any future Race Equality Action Plans put in place by the Scottish Government. d) The ERG propose that options for the status, structure, remit, staffing complement and resourcing of the Oversight Commission needs to be urgently explored, including with the full co-participation of minority ethnic people and communities.
IPP – SIR 08: Short-Term Actions – Functions	a) The functions of the infrastructure should include: Collection, analysis and publication of government, local authority, public body ethnic, and private sector ethnic minority data and evidence – Helping Directorates within Scottish Government to develop, monitor, implement and evaluate policies to reduce ethnic disparities – providing leadership to improve the quality of Scottish Government, local authority and other public bodies in their collection, analysis and reporting of data on minority ethnic groups, as well as actions to address these inequalities. Reporting regularly on the impact of policies on racialised inequality in Scotland. Creating an open data source which is kept updated in order to monitor and act on the impact of Scottish Government plans and expenditure on minority ethnic people and communities. Highlighting priority areas for investment to boost progress in affected communities across Scotland. Reporting and sharing best practice. b) As a priority, the Scottish Government should conduct an inequalities audit across the Scottish Government and other public bodies' functions. Government should work with the NHS, local authorities and other public service partners to ensure that data relating to workforce and the use of public services is accurate, comprehensive, accessible, can be ethnically disaggregated and is regularly monitored and reviewed. That work should include the investigation of any ethnic disparities. Where data disaggregated by ethnicity is not available, the Scottish Government must make the necessary investments or policy changes to address this. Any Scottish infrastructure should be multi-disciplinary, seek international guidance and expertise, especially in relation to understanding how systemic, structural/ institutional racism manifests and is sustained, as well as learn lessons from the experiences of the UK Racial Disparities Unit.
IPP – SIR 09: Short-Term Actions – Anti-Racism Actions	A) Given the new post-COVID-19 landscape and the highlighting of problems of institutional racism within the existing functions and systems of the state, there needs to be a focus on racism and anti-racism actions within the strategies and plans across the Scottish Government, local authorities and public bodies. B) The Race Equality Action Plan is due to be renewed in 2021 and to ensure that a gap is not created as a result of the Scottish Parliamentary elections next year, planning for the renewal should start as soon as possible, with a clear focus that the actions in any revised plan will be explicitly anti-racist, with clear actions, outputs and measurable outcomes
IPP – SIR 10: Short-Term Actions – Corporate Accountability	An anti-racist progress measure should be included in the performance objectives of all Scottish Government Directors and Chief Executives (or equivalent) of every public body in Scotland. This will help ensure that addressing systemic racism gets the leadership it requires and senior public sector managers will be accountable for actions taken.
IPP – SIR 11: Short-Term Actions – National Performance Framework	The National Performance Framework must include analysis and narrative on disparities for minority ethnic people within all progress reporting. Work to improve the data and evidence across Scottish Government must be undertaken and where data disaggregated by ethnicity is not available, there should be the necessary resources to make the investments or policy changes to address this.
IPP – SIR 12: Short-Term Actions – A Measure of Racism	The Scottish Government should explore the development of a workable measure of racism and discrimination and its impact on physical and mental health. This should be done in collaboration with leading international experts and be supported through a programme of rapid learning from the experiences internationally.
IPP – SIR 13: Short-Term Actions – Housing and Overcrowding:	The Scottish Government must take action with local authorities to mitigate the risk of poor accommodation or overcrowding in some minority ethnic groups, such as migrant workers, asylum seekers and Gypsy Travellers. Housing conditions have been suggested as one of the possible explanations for the disproportionate impact of COVID-19 on BME groups. In particular, the low percentage of minority ethnic people in social housing should be looked at and addressed as set out in a recent report. The report also highlights the various housing and homeless issues facing minority ethnic groups and suggests a number of recommendations, including the need to have reliable and up-to-date data and the need to close evidence gaps and identify solutions.
IPP – SIR 14: Short-Term Actions – Recovery and Remobilisation Plans, Investment Fund and Reporting:	(a) The Scottish Government should take action to ensure that COVID does not exacerbate existing racialised socio-economic inequalities, including measures to ensure that recovery and remobilisation plans do not discriminate against people from ethnic minorities. (b) The Scottish Government’s response to the Advisory Group on Economic Recovery recognised the necessity of embedding an Equalities and Human Rights approach across our policy thinking and development for economic recovery and renewal. The response recognised in the need for action in areas such as employment, skills and training, job support for young people and support for those seeking work or at risk of long-term unemployment. Opportunities for minority ethnic youth must be targeted and progressed as part of contractual agreements where public bodies are spending on significant capital infrastructure projects or modern apprenticeship programmes. ( c )The Scottish Government should take action to set up a Race Equality Transformational Investment Scheme. This fund should focus on the systemic change issues highlighted in this paper and use a participatory and empowerment model where ethnic minority communities are able to direct funding to areas of public service that need to change during the upcoming recovery and remobilisation phases.
IPP – SIR 15: Short-Term Actions – Employment	All public bodies should develop action plans with annual progressive targets for public sector employment at all levels of seniority in relation to minority ethnic groups – workplaces must reflect the diversity of the communities they serve and also set a positive leadership example. These targets should support the achievement of the existing commitment to fair representation for minority ethnic people in the Scottish Government and public bodies' workforce. Appropriate levers to encourage similar actions from the private sector should also be explored, including the potential to support community and activist-led programmes, such as "Pull Up or Shut Up,” a campaign that calls on companies to release the total number of Black employees at their companies and to identify their employment levels.
IPP – SIR 16: Changing the Cultural Landscape – Change the Curriculum for Excellence	The Scottish Government should make a formal change to the school curriculum as advocated by CRER and BEMIS. The Government should amend the Curriculum for Excellence Social Studies benchmarks to include a specific experience and outcomes measure
IPP – SIR 17: Changing the Cultural Landscape – National Museum and Statues	The Scottish Government should work with the existing group co-chaired by CRER and Glasgow City Council and community members to fund a scoping study for the establishment of a national museum dedicated to illuminating Scotland’s role in empire, colonialism, slavery, migration and the history of Scotland’s erasure of that history. Ethnic minority people, in particular people from African and Caribbean communities, must be over-represented within any such work. Further, statues have become a focus in the global moment and clarified for all that they mean, what obfuscated reality they reflect, and ask the question of what they are saying and to whom? The Scottish Government should be bold, creative, and proactive, and include young and older Afro-Caribbean and people of African descent in Scotland in any decision-making on future statues and other cultural artefacts.

IPP Recommendation Summary – Improving Data and Evidence (IDE)

IPP Summary – Improving Data and Evidence (IDE)

Link	Description
IPP – IDE 01: Improving Ethnicity Coding Through Improved Data Infrastructure – Make Ethnicity a Mandatory Field for Health Databases	This is an immediate action that should be done for one or more systems E.g. primary care databases, Scottish Morbidity Records and others. We recognise that making a field mandatory at the national level is not necessarily a panacea but in our view it is essential to improving the data in the short and longer terms. It means a valid code has to be submitted for each record in Board data submissions. ‘Refused’ and ‘Unknown’ are valid codes so even if then it does not mean it is available for all patients. At present, data held by PHS does not discriminate between these two concepts and only includes a single code for ‘refused’/’unknown’, likely including many instances when the patient was never asked. Further work is needed to understand if it is possible to create more refined categories for unknown ethnicity, requiring an improved understanding of the source data within health boards and whether the current computer systems used by health boards allow for more detailed information to be collated. In addition, mandatory does not mean accurate, any code will be accepted, and so data needs to be good quality and this needs data quality monitoring at local and national levels. Given the ownership of much data collection lies with NHS Boards, they should make it mandatory on local systems as well but this would need to go hand in hand with leadership and training initiatives described in the Lothian study and others as described above to ensure quality.
IPP – IDE 02: Improving Ethnicity Coding Through Improved Data Infrastructure – Linkage to the Census	The census currently provides the most robust information on ethnicity for the population of Scotland. Data linkage to the census should be immediately pursued by the Scottish Government to monitor the equity of the COVID-19 response in relation to ethnicity. This should not only include the immediate infectious consequences of COVID-19 (such as risks of infection, hospitalisation and death), but also secondary health harms arising from the pandemic response (such as reductions in the use of appropriate healthcare for other health conditions). If a vaccination becomes available, monitoring of its uptake by ethnicity should also be pursued using data linkage. Under the principle of collecting data once but making use of it many times, linkage to the census should be pursued to allow long-term monitoring and research of ethnic inequalities in health. At present, linkage is done for the purposes of a specific project and for this reason such analyses are often not conducted in a timely manner and are resource intensive. The ERG recommends the addition of an ethnicity field derived from the census is added to an appropriate population spine (such as the Community Health Index, CHI) which would be available for routine analyses without requiring approval from multiple organisations. This recommendation should be considered an important priority which could substantially improve data quality and facilitate timely and responsive analysis.
IPP – IDE 03: Improving Ethnicity Coding Through Improved Data Infrastructure – Develop a CHI field	Allow information to be accessible if provided to any health database only once. This will need maintenance/integration within the Community Health Index (CHI) system and a way to decide on conflicts in classification between databases over time. Similarly, some process for updating the information on an occasional basis will likely be necessary. The CHI is due to be substantially revised within the next 1-2 years, providing an opportunity to embed ethnicity within the system. This single change could make a major impact on the potential 7 for conducting analyses of health data by ethnicity, since this information would then be readily available within many health datasets. There would be considerable synergies if combined with recommendation 2.
IPP – IDE 04: Improving Ethnicity Coding Through Improved Data Infrastructure – Ethnic Group populations	Monitoring of health outcomes by ethnic group should be updated regularly and more frequently than the decennial census, as it is difficult to monitor without up-to-date populations on which to base rates. This is particularly the case in Scotland with the relatively small numbers of many minority ethnic groups and also the fact that many minority ethnic groups have relatively young populations compared to White Scottish/British and so risks can be masked by generally better outcomes in younger people if looking at outcomes at an aggregate level (Note, this was case with recent PHS Ethnicity analysis where the raised risk in South Asians was only apparent after adjustment for underlying age and sex in general population). Attempts have been made previously by NRS and ONS to look at inter-census estimates, but they appear to have stalled. A group at Leeds University have produced broad population projections for ethnic groups based on a number of assumptions (ETHPOP12). Similar work to produce inter-census estimates should be taken forward by the Scottish Government and the NRS within the next six months.
IPP – IDE 05: Improving Ethnicity Coding Through Improved Data Infrastructure – Social Care Data	At present, the provision of social care is highly varied across local authorities and data is not collected in a harmonised manner to facilitate robust analysis. There are considerable efforts to improve the quality and harmonisation of data ongoing and the inclusion of ethnicity within such efforts is important. The need for social care provision that is tailored to an ethnically diverse population is likely to increase substantially in coming years, as the proportion of older people who are minority ethnic increases. The Scottish Government and local authorities must make a clear commitment to address data deficits on ethnicity within the social care system.
IPP – IDE 06: Improving Ethnicity Coding Through Improved Data Infrastructure – Flexibility in Data Collection	The analysis of administrative data provides a number of advantages for monitoring ethnic inequalities, including the large size of datasets (which allows minority ethnic groups to be analysed) and its relative efficiency and affordability. However, administrative data will not always be appropriate and there will continue to be a need for bespoke data collection for specific purposes, including monitoring the needs of particularly vulnerable groups or when administrative data does not capture the required information. For example, migrants who have no recourse to public funds are a particularly vulnerable group and specific data collection efforts may be required to respond to their needs. Sufficient resources will need to be made available for data collection for these specific purposes. Furthermore, existing survey datasets often do not include large enough groups of minority ethnic people to allow analyses by ethnicity. Consideration should be given to the need for boosting samples of ethnic minority participants. Often there will be a strong case for collecting qualitative data to supplement the quantitative data that has been the focus of this paper.
IPP – IDE 07: Improving Ethnicity Data Collection at Source – Co-ordinated Action	A co-ordinated set of initiatives must be put in place by the Scottish Government and NHS Scotland as soon as possible building on the lessons from past successes to improve recording of ethnicity within health databases. The COVID-19 pandemic provides a clear illustration of the importance of collecting this data, so such action has a greater chance of success than in the past. These initiatives cannot be one-off projects but rather a sustained plan of action that embeds the process of ethnicity data collection in the culture of the NHS in Scotland.
IPP – IDE 08: Improving Ethnicity Data Collection at Source – Primary Care Health Ethnicity Data Collection	Collection of ethnicity information at the time of GP registration provides an opportunity for substantial improvements to health ethnicity data. The current level of completeness is low, so mandating ethnicity data collection within general practice must be taken forward by the Scottish Government. However, the pressures on general practice are considerable at this time, so there is a need to ensure partnership with GPs, the Royal College of General Practitioners and other primary care staff to explore how best to take this work forward.
IPP – IDE 09: Improving Ethnicity Data Collection at Source – Participation by Minority Ethnic People and Communities	Minority ethnic people and communities must be at the heart of any initiatives to improve ethnicity recording and closely involved in driving forward such initiatives. Minority ethnic communities racialised by the data process need to be involved to make sure it is worthwhile and not just another tick box exercise. This will help ensure the work meets the needs of Scotland’s diverse communities and also facilitate success. It should be noted that not being willing to provide ethnicity information is rare when the reason for its collection is appropriately explained. The perspectives of minority ethnic people and communities should also be brought into the data collection process to ensure greater understanding in relation to the importance of safeguarding data. Caldicott guardians should be supported to understand how racism and racialisation plays out in the systems of data collection and analysis in order to inform their responsibilities regarding the lawful and ethical processing of information. This should include awareness of the risks of both use and non-use of data.
IPP – IDE 10: Improving Workforce Data – Monitoring Workforce Data	COVID-19 has highlighted the issue of racism experienced by many of those working in the health and social care sector. While overt racism is relatively uncommon, evidence of institutional discrimination has accumulated. For example, minority ethnic groups have been more likely to report inadequate or needing to re-use personal and protective equipment. More generally and before the COVID-19 pandemic, a special series within the BMJ medical journal highlighted the systemic nature of racism within Medicine, with minority ethnic groups less likely to be promoted and occupy positions of prestige. Monitoring of the minority ethnic diversity of frontline NHS and social care staff is required urgently by NHS Scotland to be able to appropriately respond to concerns raised by employee representative bodies such as the Unison and STUC Black workers committees. In respect of COVID-19, unions identified that Black workers were disproportionately exposed to COVID risks. The experience of Black workers and others highlights both the legal duty to respond to these minority ethnic workers and also instigate transformative consultations with workers and others to respond to the experience of racialisation in our institutions and systems. NHS Scotland and public service organisations should put in place effective and sustained systems to record ethnicity of the workforce and analyse workforce data and surveys to show the variation in experience of employment by ethnic group.
IPP – IDE 11: Improving Workforce Data – NHS Workforce Data	NHS Education for Scotland (NES) are responsible for collecting, analysing and publishing NHS workforce data, and high-level ethnicity data is published annually. NES must address data quality issues and regularly report on progress in achieving equity in relation to NHS workforce issues for minority ethnic staff. This includes information on pay, promotion and recruitment. We would expect NES to monitor the quality and completeness of the data and report regularly on any gaps within that data. We would also expect the Scottish Government to provide oversight of progress on improvement.
IPP – IDE 12: Improving Workforce Data – Social Care Workforce Data	At present, no national workforce data for social care is available for Scotland, with individual local authorities responsible for its provision. Data does not appear to be regularly collated or reported and this may mean that monitoring by ethnicity is not possible within much of Scotland due to the relatively small numbers of minority ethnic people in many individual local authorities. Given the integration of health and social care, joint work by Scottish Government and local authorities is needed to ensure that minority ethnic workers are treated equitably within social care. This may require data specifications to be included within contracting processes made between commissioners and providers, informed by nationally agreed data standards. This would allow minority ethnic groups to be studied at a national level.
IPP – IDE 13: Reporting, Accountability and Governance – Reporting Data by Ethnicity	a) The COVID-19 pandemic has highlighted the need for ongoing monitoring of health (and other) data by ethnicity. The lack of reporting of datasets that are available by ethnicity can serve to make ethnic inequalities in health hidden and threatens the case for maintaining data quality. It is therefore crucial that data when available and robust enough for analysis are published and disseminated to policymakers, practitioners and communities. We recommend that: A dashboard is created by the Scottish Government to report regularly on the impact of decisions made by the public bodies on minority ethnic people and communities during the COVID-19 pandemic, this should also include data from the disruption to health and social care (second-order effects), and financial poverty (third-order effects). b) Public Health Scotland must publish an annual monitoring report on ethnic group health inequalities in Scotland. c) The National Performance Framework must include specific indicators on the impact of racialised inequalities or the impact of systemic racism on minority ethnic people to supplement the current 81 National Indicators.
IPP – IDE 14: Reporting, Accountability and Governance – Accountability and Governance	a) In order to ensure that issues on racism and ethnicity are taken seriously then people within Scottish Government, the NHS, local authorities and other public sector organisations need to be accountable for taking forward this advice and recommendations with speed and commitment. Putting a measurable racism and ethnicity objective in every Scottish Government Health Director and NHS Chief Executive’s performance objectives would provide some motivation and personal incentive to drive this forward. The ERG would be happy to discuss what these objectives could be. b) Each public body that has duties under the Equality Act should publish its scheme of governance to ensure adequate data recording, analysis and presentation of information to demonstrate their commitment to monitoring and tackling inequalities. Public bodies should do this in the interests of access, experience and outcome for services to minority ethnic groups that it provides, providing specific analysis of conditions of interest such as COVID-19, and the fair employment of staff by ethnic group using agreed indicators. In line with the reporting recommendation in relation to the National Performance Framework above, actions taken to improve indicators contained within the National Performance Framework should be publicly reported, with designated Scottish Government leads for responding to each indicator.

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