Adult Disability Payment - mobility component: consultation analysis

An independent analysis of the responses to the consultation on the eligibility criteria for the mobility component of Adult Disability Payment (ADP).


4. Planning and following journeys activity

This chapter analyses responses to questions about the planning and following journeys activity. This activity is relevant for people whose mobility is affected by mental health, cognitive and sensory impairments, and physical problems. Cognitive impairment includes orientation (understanding where, when and who the person is), attention (including awareness of risk and danger), concentration and memory.

Section 2 of the consultation asked respondents to consider the clarity of the planning and following journeys activity, to comment on feedback received about the criteria through previous research, and to explain any suggested changes to the planning and following journeys activity.

Recurring themes

In addition to the overarching themes described in Chapter 2, two further themes were raised repeatedly in responses about the planning and following journeys activity: the criteria language and expanding the definition of orientation aids.

Criteria language

Many respondents shared concerns about the language used in the planning and following journeys criteria and suggested changes. Comments included criticism of the term 'overwhelming psychological distress', which respondents found to be limiting, subjective and unclear, and suggested it should be defined, amended or removed. Similarly, several noted confusion about the meanings of 'orientation aids', 'planned', 'unplanned', 'familiar' and unfamiliar', while a few suggested 'journey' could be confusing. Respondents explained that unclearly defined or overly simplistic language makes it difficult for those responding to describe their experiences accurately and makes the job of the case managers and practitioners more subjective.

"The planning and following journeys criteria are overly simplistic and open to interpretation. One person's understanding of a 'journey' is different to another person's. It would be helpful to clearly define what is meant by a 'journey', a 'familiar journey' and an 'unfamiliar journey' and whether travelling part or all the way by public transport is part of a journey. 'Overwhelming' (psychological distress) is also subjective and open to interpretation. These criteria should be clarified." - Neurological Alliance of Scotland

CAS also noted that the criteria do not make clear that equal emphasis is given to the mental health impacts of planning and following a journey as to the sensory impacts. Stirling Council suggested improving language to include specific conditions like agoraphobia which the criteria may exclude.

Expand the definition of orientation aids

Throughout this section, some respondents requested that the definition of orientation aids include technology like satellite navigation tools and mobile phone map applications that respondents noted are crucial to their ability to move around. This was also raised in stakeholder events, where discussion included the importance of aids in getting around.

A few others also suggested that a family member or carers travelling for support should also be included as an aid regardless of whether they are acting in a supervisory role or providing another type of support.

The eligibility criteria

The eligibility criteria are used to consider how a person plans a journey, embarks on a journey, follows the route and deals with unexpected changes to the journey should they arise. Consideration is also given to the safety risks associated with the journey. Case managers will consider if the person needs prompting, supervision or assistance. Assistance can include another person, an assistance dog or a specialist orientation aid.

6. Do you agree or disagree that the planning and following journeys activity eligibility criteria are easy to understand?

Base

n=

% Agree

% Disagree

% Don't know

All answering

95

39

44

17

- Individuals

64

50

34

16

- Organisations

31

16

65

19

6(a). Please give reasons for your answer, outlining which parts you think are easy or difficult to understand and why.

Eight in 10 respondents answered Q6a, expressing mixed views on the criteria.

The most common theme was a desire for clearer eligibility criteria wording, as outlined above. Conversely, the second most prevalent theme, also raised by many respondents, was that the criteria were easy to understand, though no further detail was given to explain why they were clear. A few noted that while they understood it, they still disliked the criteria, and a small number of others compared it favourably to the moving-around criteria.

Several respondents suggested other factors to include in the criteria, such as references to confusion and brain fog, a change in the points-based system, further consideration of activities that cannot be done unaccompanied, and the inclusion of safety risks.

While not directly related to the activity, some respondents provided a critique of the application layout and accessibility. A few were concerned the photographic examples only represented people with physical conditions. A small number of others highlighted problems with the form length, and one noted that they could not access the forms online.

Both overarching themes mentioned at this question and less commonly mentioned themes about the criteria are in Appendix D.

6(b). How could we make the planning and following journeys activity eligibility criteria easier to understand?

Just over half of respondents provided an answer to Q6b. The vast majority raised themes described elsewhere in this report. These include improved language clarity, more holistic decision-making, broadening the criteria to include conditions such as such as autism, cognitive impairment and dementia, and expanding the definition of orientation aids.

Other suggestions each raised by a small number of respondents included:

  • To collaborate with stakeholders to develop criteria which reflect their experiences.
  • Criteria that acknowledge the safety and risks associated with the journey.
  • Make the criteria more inclusive of those with fluctuating conditions, such as variable mental health conditions or cognitive fatigue. The stakeholder events also highlighted sensory issues that can vary depending on external conditions, such as poor weather or changing daylight hours throughout the year.

"We are calling for the application process to be modified to encourage a greater understanding of its application to those with mental health conditions, framed in a manner that elicits a complete picture account of a claimant's mobility needs, not of "good day", "bad days" or even "average" days. Such modifications must be developed through a genuinely inclusive co-design process." - CAS

Evidence on the planning and following journeys activity

Research collected by the Scottish Government notes previous opinions and positions held by stakeholders about the planning and following journeys criteria. These include suggestions that overwhelming psychological distress is an overly strict way to measure a person's ability to plan and follow a journey, as well as critiques of the 'planned' and 'unplanned' journey language. The consultation paper describes this research.

7. Are there any other issues with the planning and following journeys activity that we have not captured above?

Base

n=

% Yes

% No

% Don't know

All answering

91

55

23

22

- Individuals

60

45

25

30

- Organisations

31

74

19

6

7(a). If you said "yes", what other issues with the planning and following journeys activity do you think need to be considered?

Further consideration of mental health

Around half of respondents answered Q7a, with the most common theme, suggested by several, being a need for greater consideration of mental health in relation to this activity. These comments often focused on clients' experiences during the journey, such as impacts on mental health if the journey does not go to plan, or anxiety related to specific types of journeys but not others. Crohn's & Colitis UK noted that a sudden need to use a toilet mid-journey might lead to heightened anxiety about leaving the house in the future.

Other specific considerations

Some suggested specific issues not already captured by the research including:

  • Inclusion of safety or steadiness measures.
  • Adjusting the points system to allow higher scores for the descriptors in the criteria.
  • Support in the application that explains mental health conditions are also considered alongside physical or sensory conditions.

Beyond this, most other comments reflected the overarching themes, and included giving further consideration to the additional impacts of planning and making journeys, reflecting the realities of the built environment in the criteria, expanding the definition of orientation aids and taking a holistic approach to criteria and decision-making.

7(b). In your view, what are the positive aspects of the planning and following journeys activity that we have not captured above?

A quarter of respondents answered Q7b. The most common theme in their comments was that there were no additional positive aspects that had not been captured in the consultation paper. However, a few respondents were positive about the changes to the application process, including the inclusion of carer perspectives and the support options for those applying.

Improvements

The Scottish Government has made improvements to the application form for the planning and following journeys activity. The guidance now includes photographic examples and more detailed prompts for certain questions. Changes have also been made to the decision-making process. These include removing the Mental State Examination, ensuring people conducting consultations are practitioners with two years of experience and providing guidance for case managers that focuses on building a more holistic evaluation of the impact of a disability or condition on a person's ability to plan and follow a journey. For complete details of all changes, please refer to the consultation paper.

8. How effective do you think the planning and following journeys section of the application form is at helping us understand a person's ability to plan and follow journeys? Please give reasons for your answer

Base

n=

% Very effective

% Effective

% Somewhat

% Not very effective

% Not effective at all

All answering

87

10

22

41

22

5

- Individuals

61

13

26

44

15

2

- Organisations

26

4

12

35

38

12

Support for the application form

Two-thirds of respondents commented at Q8a. The most common theme, highlighted by many, was support for the effectiveness of the planning and following journeys section of the application form. Several noted that the ADP application form was clear, while a few noted it was an improvement on the PIP form. Some others suggested the form was more inclusive of those without physical disabilities and clearly spoke to those with mental health conditions. Clarity around the definitions of familiar and unfamiliar journeys was welcomed by some, and others liked the use of photographic examples. Some felt the application was compassionate and more representative of lived experiences.

"I'm relieved to read this. It's much more representative of my daily struggles. It is so much more compassionate. Thank you." – Individual

"The examples given of the difference between familiar and unfamiliar journeys are reasonably clear and useful if that distinction is to continue to be drawn. In addition, the prompt with a list of mental health conditions that may result in anxiety about travelling may help make clear to applicants that there are legitimate and understood reasons they would feel that way, although these could be supplemented with specific reasons people may feel anxious as outlined in our response to the previous question." - Health and Social Care Alliance Scotland

Other themes

Most other comments aligned with the overarching and recurring themes described elsewhere in this report. In addition, a few respondents described the application form as inaccessible, specifically due to the length, and a few others called for access to advocacy and welfare rights assistance when completing the ADP application.

9. What impact do you think the changes to how we make decisions on the planning and following journeys activity have on understanding a person's ability to plan and follow journeys? Please give reasons for your answer

Base

n=

% Significant Positive

% Positive

% Neither

% Negative

% Significant Negative

All answering

79

19

46

27

6

3

- Individuals

55

25

44

22

7

2

- Organisations

24

4

50

38

4

4

Support for removal of DWP-style assessments

Just over half of respondents gave an open comment at Q9. The most common themes were positive feedback about the removal of DWP-style assessments, and support for the decision to use professionally trained practitioners over assessors for ADP. A few caveated their support of the changes with further recommendations and suggested improvements, such as shortening the length of the application, and there was still a concern that while the application process may be more dignified, the criteria remained unchanged.

"Having someone who understands the condition is simply fair. Having suitably qualified people is a major step forward." – Individual

"The changes to the criteria for planning and following journeys are welcome as evidenced in the consultation document. We welcome the removal of the mental state examination and where a review is necessary, for this will be conducted by a qualified professional. The application process is important in this regard as it must take a more holistic approach to the current UK Government Personal Independence Payment (PIP) application and ensure the principles of dignity and respect are upheld." - Sight Scotland and Sight Scotland Veterans

Other positive feedback

Several respondents noted their approval of the new process, suggesting it is better, improved and "a good thing" compared to PIP. Some mentioned they found the application more inclusive and holistic, allowing case managers and practitioners to gain a well-rounded picture of those individuals applying. A few approved of the ability to include support from carers, family members and professionals. One anonymous individual suggested it was more understanding, and another noted their approval of the included photographic examples.

10. If there was an opportunity to change any specific aspects of the planning and following journeys activity, what changes would you make (if any)?

10(a). If you proposed changes, what positive impacts could these have, and for who?

10(b). If you proposed changes, what negative impacts could these have, and for who?

Six in 10 respondents answered Q10. The most common theme, proposed by several respondents, was a desire for a more flexible, person-centred approach to the application and review process. The recurring theme of clearer language was raised by some.

Other suggested changes

Specific suggestions were provided by some respondents, and these included: a desire to separate planning and execution aspects of journeys in the criteria; consideration of whether an individual can drive or if they depend on public transport; inclusion of more types of orientation aids; introduction of a discretionary "safety net" similar to that created in the Universal Credit Regulations 2013; and an extension of full points to an individual that requires prompting or companionship to undertake a journey.

A clearer consideration in the descriptors of those with mental health conditions was recommended by some. Respondents did not specify how they would adjust the criteria, though CAS suggested greater understanding could be achieved through reframing the discussion of mobility needs, moving away from the "good day", "bad day", and "average day" language. They also recommend that changes should be "developed through a genuinely inclusive co-design process".

"Descriptors within the eligibility criteria continue to read as more relevant to an individual with physical disabilities. Wording or descriptors which better reflect the needs and challenges of individuals with mental health conditions and other impairments, including dementia, are encouraged. As alluded to, providing a clearer definition of "overwhelming psychological distress" could help with this." - About Dementia, Age Scotland

Specific suggestions or comments, each raised by a few, are listed in Appendix D

Positive impacts

Just over one third of respondents answered Q10a, and just under one quarter Q10b. Several respondents stated there would be no negative impacts from their suggested changes but did not provide greater detail. Several others described the positive impacts of their proposed changes to the planning and following journeys activity. These included:

  • An improvement to the wellbeing of those applying due to, for example, a more supportive, understanding, less bureaucratic process which reduces anxiety. Another respondent noted that their suggestion would limit the explanations those applying would have to provide, which can be upsetting.
  • An easier application which provides greater clarity of language and a more manageable size.
  • More supporting information being collected being data, which would help the client explain their conditions fully and allow case managers greater clarity in making an award.
  • Improved outcomes for clients suggesting more would receive awards, or awards would be more fairly given. One individual suggested that Social Security Scotland could benefit from cost savings due to fewer appeals being lodged.

Respondents noted that their suggested changes would have positive impacts on specific groups. Some mentioned that those with mental health conditions would benefit, and a few others suggested improvements would benefit those with fluctuating conditions. Respondents said the process would feel more supportive and inclusive for both groups and help clients receive a fairer award. Other groups mentioned included: neurodiverse people, those who cannot leave home, people with Crohn's disease and ulcerative colitis, people with neurological conditions, and those whose conditions are unlikely to change.

Negative impacts

Few negative impacts were identified. A small number of respondents noted that the workload and costs for Social Security Scotland could increase due to amended application processes. A few others reiterated that any application process was overly bureaucratic and stressful for those applying, regardless of changes. One individual noted that those who can receive treatment which can improve the ability to plan journeys might feel penalised if the weighting of points for planning and execution of journeys are considered separately.

Contact

Email: ADPreview@gov.scot

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