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).

Appendix C: The moving around activity

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

Clarity of the criteria

This theme is discussed in the main report but additional quotes are included below.

"People who are new to the benefits system do not realise - and the form doesn't tell you - that the issue is not just how far you can walk, but whether you can do it "reliably" i.e. safely, to an acceptable standard, repeatedly and in a reasonable time. While the form highlights pain, fatigue and breathlessness, it does not mention speed, issues with gait or uncontrolled movement which may mean that people are not moving to "an acceptable standard", or the need to be able to repeat the distance - all of which are common for people with Parkinson's." - Parkinson's UK Scotland

To be made easier to understand, panel members felt that the system and criteria needed to be made more distinct from the existing DWP assessment, which does not reflect enough about what real life is like as a disabled person, so the questions in the criteria need to be re-written… Linked to this, the questions in the eligibility criteria, which are based on statements such as "Can stand and move more than …" are also focused on very prescriptive, yes and no answers and not descriptive ones, thus do not seem to be a genuine attempt to gain an understanding of the needs of the individual." - EEPPIC

Less commonly mentioned themes

A few respondents each mentioned the following points:

  • Specific changes to the criteria, including universal access to advocacy to assist with the application and regulations in line with case law, which are addressed more in Q2b.
  • Critique of the criteria as it relates to 'aided' or 'unaided' movement, with respondents noting that those who move unaided should not be considered the same way as those who need an aid to move.
  • The negative impact of not being entitled to ADP and therefore not able to access other passported benefits, such as the blue badge scheme and the Accessible Vehicles and Equipment Scheme.
  • Negative comments about the training, attitudes, and skills of DWP assessors, including poor advice given during DWP-style assessments and a lack of understanding about the experiences of disabled people or those with health conditions that impact mobility.
  • Generally negative comments about ADP, without providing specific details.

1(b). How could we make the moving around activity criteria easier to understand?

Some respondents each raised the overarching theme of considering the wider impact on clients of moving around, or called for the language used in the eligibility criteria to be simple, unambiguous and consistent but did not provide any further detail.

A few respondents each raised overarching themes of ensuring the criteria are more reflective of real-life situations or recommending other considerations to broaden the criteria.

Other points made by a few respondents included:

  • Negative comments about the training level, attitudes, and skills of practitioners, though it was unclear whether respondents were referring to DWP assessors or Social Security Scotland practitioners
  • A critique of the use of distance measures: in particular, the '20-metre rule'.
  • One respondent suggested the Scottish Government should further engage stakeholders when amending or changing the criteria.

2 (b). In your view, what are the positive aspects of the moving around activity that we have not captured above?

"We note that you have talked about disincentives to physical activity, and we want to highlight that this is a particular issue for our community… There is increasing evidence that physical activity can help people to live better with their Parkinson's, including managing mood and even some motor symptoms. But many people have told us that they are scared that they will be seen as scamming the system if they take part in physical activity - creating a barrier to keeping well." - Parkinson's UK Scotland

"Adult Disability Payments should be based around the principle of enabling someone to live as independently as possible with a good quality of life and discouraging people to be active may have a negative impact on health and wellbeing." - Sight Scotland and Sight Scotland Veterans

"It was particularly concerning within the consultation document to see that two-fifths of respondents to a survey were effectively discouraged from being active due to the fear they would lose their entitlement to social security. The health benefits, both physical and mental, arising from exercise or otherwise being active are well known." - Health and Social Care Alliance Scotland

4. What impact do you think the changes to how we make decisions on the moving around activity have on understanding a person's mobility needs? Please give reasons for your answer

Support for change

"This can also reduce the stress and anxiety on applicants by removing the automatic requirement for a consultation, therefore creating a more dignified approach to assessments." – Scottish Association of Social Work

Other themes

Some organisations reserved judgement on the changes until they can collect more data on the process, impacts on clients and the decisions being made.

The practitioner, particularly the training and professional qualifications of the practitioner, was a concern for some respondents. A few acknowledged that the change to consultations improved upon the otherwise subjective nature of DWP-style assessments. However, a few others highlighted that supporting information would add little to the process if the practitioner is not trained to read and understand it.

"Will the team assessing the applications have medical knowledge and be in a position to be able to interpret the information provided? There is no point in being given a copy of a prescription if the person assessing for the award has no medical training." - Individual

Some noted continuing concerns over the application and consultation processes. These included a fear that people who do not deserve ADP will be awarded it and that the changes do not go far enough. CPAG in Scotland raised concerns about a legality that allowed Scottish Ministers to refuse to undertake a determination without application (DWA) if a client requests a review of their award. As CPAG notes, "in this situation the individual would have no right of appeal against this decision."

The overarching themes of considering the wider impact of moving around and broadening the eligibility criteria were repeated by some respondents at Q4.

A few respondents each mentioned technical and accessibility issues such as issues with the digital portal or problems with uploading material, and that they found the application itself to be overly long and repetitive to complete.

5. If there was an opportunity to change the moving around activity criteria, what changes would you make (if any)?

Specific suggestions or changes to the criteria

  • A consideration of the length of time taken to move was suggested by a few to get a clearer picture of a person's ability to move.
  • Two respondents recommended further consideration be given to the application process for people with incurable or progressive conditions.
  • An individual suggested home visits be included for consultations, while another recommended an option to upload a video.
  • Health and Social Care Alliance Scotland provided rewritten criteria that expanded on the distance measures to include other factors, such as a person's ability to move around their own home, local area, and "other places they may frequent in daily life such as their place of education or employment, shopping and leisure facilities, and healthcare services."
  • MS Society Scotland acknowledged the improvements to the criteria but called for future changes to be co-designed with clients.

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

Positive impacts of suggested improvements

"Mostly this type of change would affect those like myself who are wheelchair users, even those with a Zimmer. It would help those affected in this way feel like every aspect is being looked at and considered, and those with the most need do truly receive the help needed. As a wheelchair user from birth, I've learnt tricks and skills in managing to get around, and due to this I do try to continue working with adjustments to be an effective contributor within my community. During these assessments it feels like this goes against you; the fact you're trying to find ways around barriers excludes you from getting this award whereas those who don't try seem to pass the assessment much easier, which to me seems the wrong way round. Minimizing an individual's life instead of maximising it, which this benefit can and should support, so I agree with the studies that disabled people can feel very afraid to even try and do well." – Individual



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