In the twenty years since the devolution arrangements the four nations of the UK (England, Scotland, Wales, Northern Ireland) have gone their separate ways with their care arrangements. Research that we are conducting for the ESRC Sustainable Care programme, highlights the different principles which are shaping care systems in the four areas. From initial conversations with policy makers in the four areas it is clear that:


Scotland has developed self-direction as a principle of care services, distinct from the more market-oriented personalisation that they see across the border in England. Free personal care for the over 65s has also been a distinct feature of the Scottish system, embedded in law since 2002, and has recently been extended to working age adults under Frank’s Law.

For Wales, well-being is a key underpinning principle of its public services, embodied in two recent pieces of legislation: the Social Services and Well-being Act 2014 and the Well-being of Future Generations Act 2015. Like Scotland, Wales has been keen to distance itself from the marketised care system of England, and has emphasised a co-productive approach to care.

In Northern Ireland, the current political impasse is limiting the scope to update the care system, for example by extending carers’ rights to bring them into line with other parts of the UK. Conversely, Northern Ireland is ahead of the other nations in having a long history of health and social care integration (brought in during the 1970s). This provides useful learning for the other parts of the UK, all of which are pushing on with plans to integrate health and social care.

Map of the UK in Blue

In England, debates about who should pay for care services dominate the agenda, along with concerns about the viability of a care system which is more privatised than in the other areas of the UK. Another feature of the English system is the higher prevalence of self-funders which provide cross-subsidisation funds which are vital to the sustainability of many residential services, and give the market a distinctive character compared to the devolved nations.

The ‘natural experiment’ idea of comparing the four nations, 20 years on from a common starting point in 1998, has been one of the first casualties of our project. It is clear that the four countries did not have the same care systems in 1998. This is partly because of historical patterns of service difference and partly due to demographic characteristics. It is also due to the extent to which what it means to care is embedded in conceptions of self, family and community: each of which is part of the sense of distinctiveness of the four nations. Through the project we are exploring how best to categorise the four within broader care typologies. It is also important to recognise that some key policies which affect the care system are still retained at the UK level (such as immigration, disability benefits and statutory care leave).

We are also exploring the extent to which the borders of the four nations are the best way to conceptualise different care regimes within the UK. Although social care policy is devolved, important questions about what people see as the appropriate role for families, communities, markets and the state in caring may link to social differences not best be explained by borders: might it be that rural areas in the four are more similar to each other than they are to urban areas? Do deindustrialised areas all share common features that the more economically advantaged, demographically transient areas do not? How does multiculturalism, evident in some areas of the UK, but much less so in others, overlay attitudes to care and the care workforce? These are some of the issues we will be exploring over the next two years.

Patrick Hall profile picture

Patrick Hall

Research Associate

In the Sustainable Care programme, Professor Catherine Needham and Patrick Hall both work on Comparing UK Care Systems: prospects, development and differentiation in the four UK nations, to read more about their work, click the image below

Comparing UK Care Systems

prospects, development and differentiation in the four UK nations