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).

3. The moving around activity

The moving around activity considers a person's ability to stand and move specific distances without severe discomfort. While this considers movement on flat and outdoor surfaces, such as pavements and kerbs, it does not consider walking up slopes or stairs. The criteria consider how easily a person can stand and then move up to 20m, up to 50m, up to 200m and above 200m. Application guidance asks clients to consider factors that affect their experience of moving around. These include: how quickly a person can move; the risks of falling or injury; breathlessness, pain or fatigue; the way a person moves; and symptoms or side effects from moving around. Clients are scored on a 0-12 point scale depending on how far they can stand and move.

Respondents were asked to consider the clarity of the moving around activity criteria, to comment on evidence available about the activity, and to suggest changes to criteria.

The criteria for the moving around activity

1. Do you agree or disagree that the moving around activity criteria for Adult Disability Payment are easy to understand?



% Agree

% Disagree

% Don't know

All answering





- Individuals





- Organisations





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

Around eight out of 10 responded to Q1a. The most prevalent theme across comments was to consider the additional impacts of moving around alongside distance measures. Several argued the criteria are inappropriate for those with fluctuating conditions. As these are described in the previous chapter, we do not discuss this again in this section.

Clarity of the criteria

Clarifying the language or meaning of the criteria was the second most common theme, mentioned by many. Some stressed the importance of using examples, such as distances applied to real life scenarios or a specific number of steps, as clients could find it hard to imagine what walking the distances meant for their mobility and health.

A few consultation respondents and event attendees also suggested using videos. Others highlighted confusion around the wording on aided and unaided moving and indicated that the first part of the criteria measures only unaided movement, while the introduction of 'aided' in Criteria C creates further complexity. Some requested further clarity around specific factors that may inhibit movement to ensure consistent application of the criteria.

"This assessment has to consider the ability of an applicant to be able to move around 'safely', 'to an acceptable standard', 'repeatedly' and 'within a reasonable time period'. The determination of how these factors affect a claimant's ability to move around provides significant discretion in how a Social Security Scotland assessor understands and assesses a claimant's individual ability to walk around which sets the conditions for disparity in decision-making assessments." - Alzheimer Scotland

Positive comments about the criteria wording and other changes

Positive, supportive comments were provided by several respondents, two thirds of whom were individuals, about the criteria wording, the examples provided, and changes from PIP to ADP. Respondents described the criteria as straightforward, easy to understand, and clear, with one respondent stating the criteria benefitted from the added context provided.

"The way it was explained in the accompanying information seems clear. It's plain English and seems to try to explain more complicated questions clearly." – Individual

Less commonly mentioned themes

  • Each of the overarching themes described in Chapter 2 were mentioned by some respondents in relation to the moving around activity.
  • The '20-metre rule' was mentioned as unfair and limiting by some respondents. Their views are included and presented in the analysis of Q5 below.
  • A few respondents mentioned specific points which are summarised in Appendix C.

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

Around two thirds answered Q1b. The most common theme was calls for a flexible, holistic approach to the application and decisions. There were also frequent requests for a clearer definition of mobility and better examples, to make the criteria easier to understand.

Clearer definition of mobility

The second most prevalent theme, raised by several, was that the criteria would benefit from a clearer definition of what moving means. A few respondents specifically requested clarity on the difference between 'aided' and 'unaided' movement. Respondents suggested using open questions that ask about movement, what people rely on to get around, and how people get around such as speed and with what aids. This was felt to help clients provide clarity or information than the current question allows. In contrast, a few respondents provided positive feedback on the clarity of the criteria.

Less commonly mentioned themes

The explanation for the distance measurement was described as confusing by some. There was support for including grounded, real-world examples, such as distances in relation to parked cars or buses, football pitches, length of a sofa or supermarket aisles. One respondent noted that older people might not think in metres, suggesting imperial measures also be included; another suggested making a video to provide examples. It should be noted that a few of those raising this issue in Q1b later gave positive feedback on the example image now being used when presented with these in Q3.

Some called for greater consideration of the danger, fatigue and pain of moving around, as well as how reliably clients can move set distances consistently. A few acknowledged the change in the criteria, but others requested clarity about what levels of pain and fatigue are considered reasonable. An individual recommended changing the question wording that a person should be able to move around 'safely, confidently and without fear'.

Other themes raised in Q1b are summarised in Appendix C. These were primarily the overarching themes or points raised by a small number of respondents.

Evidence on the moving around activity

Research by the Scottish Government helped to inform the development of ADP and subsequent changes to the application and consultation. The research also provided greater understanding of issues with the moving around activity which are summarised in the consultation paper. Respondents were asked for their views on any additional issues.

2. Are there any other issues with the moving around activity that we have not captured above?



% Yes

% No

% Don't know

All answering





- Individuals





- Organisations





2(a). If you said 'yes' what other issues with the moving around activity do you think need to be considered?

Just over eight in 10 respondents answered Q2a. Reflecting the focus on improvements, the four most common issues raised were the overarching themes outlined in Chapter 2.

Improvements and considerations for the application process were suggested by some respondents. These included asking clients to keep a diary to provide greater detail on their mobility on a day-to-day basis, and providing independent advocacy services and advice to all clients. In response to Q2a, one anonymous respondent noted that there should still be an 'it varies' option, allowing people with fluctuating conditions to describe their experiences more accurately. Other suggestions included:

  • SCoRSS (Scottish Campaign on Rights to Social Security) and Citizens Advice Scotland (CAS) called for transparency about the pros and cons of different assessment methods. They highlighted early evidence that remote assessment poses 'significant challenges to decision-making where direct observation and interaction with a claimant in person would be helpful'.
  • CPAG in Scotland and a joint response from The Action Group & VOCAL & Grapevine at Lothian Centre for Inclusive Living asked for further clarification in the descriptors regarding movement that is aided and unaided in relation to case law[1].
  • ENABLE Scotland called for an approach like the 'exceptional circumstances' regulation as part of the work capability assessment, which would treat a person as though they meet the required number of points.
  • One Parent Families Scotland recommended using open ended questions to gather a better picture of individual experiences.

Suggestions to improve the application process were shared by some respondents. These included: reducing the length of the application, providing options for those who are unable to fill out the form, and considering alternatives options to address digital exclusion.

A few respondents endorsed the proposed changes, highlighting positive features such as support for the person-centred approach, or suggestions that practitioners receive further training. Some highlighted why this is important by giving past examples of where their supporting information had been dismissed or they were not listened to.

MS Society Scotland's Survey Tool Responses

The survey tool automatically populated Q2 as Yes for all respondents, followed by the question: "What issues have you experienced with the 20m rule and the ADP/PIP application process?"

Almost all those using the survey tool provided an answer to this question. The responses were included in the overall analysis of the question and while the question wording was different, many of the responses provided via the tool aligned with the views of those who responded to Q2a via Citizen Space. However, the prevalence of these themes varied. The most common themes in response to this question in the tool are summarised below:

Comments about fluctuating conditions: Given the variable nature of MS symptoms, there were frequent calls to clarify how the criteria consider and include clients who may be able to walk a certain distance one day but not the next.

Critique of distance measures: Many criticised the '20-metre rule' as limiting and unfair:

"I can walk 20 m sometimes, but that's all well and good, but I cannot guarantee to be able to get back. Therefore it means that I am, in reality restricted to 10m or less, particularly if I'm going to a shop and have to stand in a queue. The 20m is a farce." – Individual

Consider all aspects of mobility: Many noted the impact of moving could be felt for hours, days or weeks and called for this to be considered in the moving around criteria.

Personal experience: Several described their own circumstances or experiences at this question, either in relation to their previous applications or in relation to daily life.

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

Respondents were asked to reflect on the research on the proposed changes to the criteria for the moving around activity. Just under half provided an answer to this question. The most common theme, raised by several, was that there were no positive aspects.

"We acknowledge the Scottish Government have made an attempt to mitigate the impact of using these eligibility criteria by introducing changes to the application and assessment processes. However, these changes will have minimal impact as applicants are being assessed against the same criteria. If you can walk 25 metres, you still won't be eligible for the highest number of points regardless of the changes to the application and assessment process. Ultimately if you ask the same questions, you will receive the same answers and these answers are assessed using the same criteria as PIP." - MS Society Scotland

While not directly answering the question, some respondents highlighted that fear of the system has a negative impact on the mental and physical wellbeing of clients. Reiterating a point raised in the consultation paper, a few suggested that the criteria may deter people from attempting physical movement that could improve their mental wellbeing or the symptoms of their condition, which was also reflected in event discussions. Two respondents commented on the importance of practitioner and case manager training in maintaining a sense of trust and respect with clients.

Rather than providing positive aspects of the criteria, other respondents typically reiterated the overarching themes, for example, some requested a more flexible approach that acknowledges the unique circumstances of each client or recognition that not every client will fit into specific boxes.


While the eligibility criteria for the moving around activity have not changed, the Scottish Government has sought to make the application form guidance clearer. Examples of these changes include the use of examples, images and prompts to help clients understand the criteria and help practitioners and case managers better understand clients' experiences. Social Security Scotland has changed the guidance for people applying for ADP and for the case managers. These changes are intended to consider environmental, cultural and social factors more fairly and consistently when making decisions.

3. How effective do you think the moving around section of the application form is at helping us understand a person's mobility needs? Please give reasons for your answer



% Very effective

% Effective

% Somewhat

% Not very effective

% Not effective at all

All answering







- Individuals







- Organisations







Support for changes to the application guidance

The most common theme in open responses from the nine in 10 respondents who answered Q3 was appreciation of, and support for, the visual examples in the application form. Many felt the images provided a real life context to what may seem an abstract distance to some clients. A few said prompts could help clients to provide a holistic view of their condition; a small number of others commented that the changes mean the ADP form is a clear improvement over PIP due to the improved guidance and the use of images.

"Simply showing distances compared to the spaces in a car park is a very good means of helping people judge how far they can walk rather than giving a distance such as "200 metres" which probably means nothing to the person filling in the application form." – Individual

"The prompts are also a good addition - things can be easily forgotten in the stress of completing these forms." – Individual

Overarching themes

In comments on the application form, several suggested there should be broader criteria to consider moving safely, mental health, use of different aids, and life in rural and urban environments, and more space for clients to detail the wider impacts of moving around. Some also noted that experiences of variable or fluctuating conditions felt excluded from the question guidance.

Critique of the images

The lack of clarity in images was mentioned by several respondents. Some referred to the overall image quality, others criticised the car park image as lacking relevance to non-drivers or suggested an overhead perspective would be clearer. CAS noted that the car park examples confused some clients. Event attendees suggested creating a video.

Suggested changes to the questions

Examples were provided by several respondents of factors they would like added or changed in the application questions. A few suggested moving away from yes and no questions and allowing free space for open responses that could add nuance. A few others suggested using a more holistic approach to decision-making.

A few respondents highlighted the need for clarity in aspects of the question, such as rephrasing unspecific language like "some or all of these things' or 'this can be done by yourself or with help' i.e. what does 'with help' mean.

"OPFS would ask that the wording of the questions be reviewed, and more emphasis be placed on allowing claimants to provide details of their condition and the effect this has on their mobility as individuals rather than them trying to fit their circumstances around fixed narrow descriptors." – One Parent Families Scotland

Suggested changes to the application process

Concern about the application process was raised by some and reiterated at events. Comments included that the application form is long, intimidating and confusing. A few argued that the process causes anxiety and may put clients off completing the process.

"Length of application (the combined application is 100 pages long and the section on Moving around is from page 90 near the end). There is the risk that people will be too tired, lack awareness or not have the support needed to either complete the application form or provide the necessary additional information, beyond the space in the application form. There is also the risk that people won't complete an application, due to the level of anxiety that is caused by going through this process and the risk to their mental health being too high. The application was regarded as not easy to complete for those with a learning disability or difficulty and would result in excessive pain and impact for someone with a chronic pain syndrome." - Experts by Experience Panel of the Poverty and Inequality Commission (EEPPIC)

Negative feedback on the changes

Some respondents provided negative feedback on the changes to the question guidance. These included a feeling that the questions do not adequately cover or apply to all conditions; one suggested imperial instead of metric measurements should be used.

The MS Society Scotland's Survey Tool Responses

The survey tool asked respondents to answer the question: 'How effective is the '20-metre rule' as a way to judge mobility?' While this populated the answer space for Q3 in Citizen Space, the question asks respondents to concentrate specifically on the 20-metre criteria rather than the changed guidance as a whole. For that reason, the most common themes were different to those raised by other respondents in Q3. Almost all respondents answered this question.

Negative feedback on the '20-metre rule': Many answered the survey tool question directly, with the most common theme being the ineffectiveness of the '20-metre rule'. Many described the criteria as poor, unsuitable and unreliable for judging mobility.

Consideration of fluctuating conditions: The '20-metre rule' was disliked by many for not considering those with variable or fluctuating conditions. They noted that there were days when clients could walk more than 20 metres and others where could not. Some suggested consideration of 'worst days' or 'bad days' rather than 'average days'.

Lived experience of moving around: Many highlighted that the 20-metre criteria does not consider the impact moving around has on clients. As outlined at the start of this chapter, this can include the physical and mental toll of moving around, the preparation required to move, and a reluctance to move when the impact of doing so is extreme.

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



% Significant Positive

% Positive

% Neither

% Negative

% Significant Negative

All answering







- Individuals







- Organisations







Support for changes to the guidance

Of the eight in 10 who answered Q4, the most common theme was positive feedback on the changes to the ADP application guidance. Respondents thought the changes would lead to more accurate decisions, allowing clients to receive benefits that fit their needs and said a more individual approach was more understanding, fairer and truer to life. A few argued it would make the process less stressful than previous experiences with PIP.

"As someone who has experienced both the PIP and ADP approaches, the ADP process blows the PIP process out into the stratosphere in regard to being far more humane. I don't feel like I'm being asked trick questions, even if some are still weirdly phrased. I also feel like I'm much more capable of getting in contact with Social Security Scotland for any reason at all, without being judged or put off by negative attitudes or stereotyping by any of the staff, assessors, case managers, etc." – Individual

Support for changes to the consultation process

Several approved of the move from face-to-face assessments to only using a consultation with a practitioner when there is no other practicable way to understand a client's needs. Reasons for support included: that it makes the process less stressful; reduces clients' mistrust of previous assessment processes; and addresses concerns that some clients attending a DWP-style assessment were being informally assessed without being made aware of it. Conversely, one individual preferred consultations as they could be more accurate than knowledge provided by GPs.

"The changes to guidance for decision-making processes is welcome, particularly in relation to assessors making observations and assumptions outside of consultations. We agree observations should only be made during the official consultation and the applicant must be informed as to when this has begun." - Sight Scotland & Sight Scotland Veterans

Gathering information from professionals

Several were in favour of gathering supporting information from professionals who support those applying for ADP. They highlighted that it would provide a more rounded picture of clients and allow contributions from professionals who understand the client's situation clearly.

"We support the positive shift in guidance around the collection of further supporting information on an individual before a decision is made. Information from a GP or a support worker may work to provide a more well-rounded view of an individual's needs. Additionally, the inclusion of equal consideration given to information from a person's family, carers, or friends weighing into the application decision is a positive move to recognise the knowledge unpaid carers and family members may have about a person's needs." - Age Scotland

However, several respondents noted issues with ADP case managers gathering information to support the application, in particular, from health professionals. Some noted concerns about the quality and accuracy of notes from GPs or social care workers who may only see clients occasionally or know little about their specific conditions. It was also noted that some people choose to not interact with medical or care professionals and so would not be able to source supporting information to support their application.

"For chronic conditions many patients see GPs and doctors rarely. This can make providing info difficult." - Individual

A few others requested that supporting information be sourced from professionals who may be more aware of the condition of those applying, such as third-sector groups that assist with care, nurses, clinicians, and specialists. SCoRSS and CAS highlighted a concern about the lack of clarity in the application form about process for gathering supporting information. Glasgow City Council also had concerns that gathering supporting information may lead to delays in awards.

Other themes

A concern that the changes still did not reflect the lived experiences of those with fluctuating or variable conditions was mentioned by several respondents, specifically the 'average day' language, although it was unclear whether they were referencing previous PIP guidance or ADP.

Less commonly mentioned themes detailed in Appendix C include:

  • The need to wait until more data about decision-making is available.
  • Concerns about the training and qualifications of practitioners.
  • Concerns about the application and consultation process.
  • Technical and accessibility issues with the digital portal or uploading material.

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

Respondents were also asked to suggest their own changes to the moving around activity criteria. After changes to the distance measures, the three next most common themes in changes proposed were the overarching themes in Chapter 2.

Proposed changes to the distance measures

The most common theme among the nine in 10 respondents who answered Q5 was a desire to change the distance measure in the moving around activity. These responses ranged from eliminating the 20-metre measurement in the criteria – the '20-metre rule' - to not using any distance measures. Respondents who supported eliminating or changing the '20-metre rule' argued 20 metres is an unrealistic and limiting distance and that those who move only 50 metres have a high degree of immobility and deserve and need the highest level of ADP support.

"I would change the distance criteria from 20m for the highest level of support to 50m for the highest level of support, in recognition of the fact that a person who can only walk 50m is experiencing an extremely high level of impairment with respect to mobility, and that 20m is not sufficient to accomplish anything beyond moving a little around the home." – Individual

"More important than the cost of the '20-metre rule' to the Government's budget was the cost in independence enjoyed hitherto by disabled people. Far too many people in the MS community have lost out because of the '20-metre rule'. Since PIP began to replace DLA in 2013, around one in three people with MS moving over to this benefit have had their support downgraded, including one in ten who have lost support altogether" - Cross Party Group on MS

"The restrictive element of the '20-metre rule' has caused unnecessary stress and in most cases, has exacerbated their PPS symptoms... The recommendation is to increase the distance to a more realistic 100-200 metres, or indeed to take away the requirement altogether." – Scottish Post Polio Network

Those who supported eliminating all distance measures wanted a system that focuses on the qualitative aspects of movement, i.e., how people move, captured through open-ended questions and a flexible approach to criteria dependent on people's real life experiences.

"I would make the question much more open. Instead of asking people to choose an arbitrary distance, I would ask them how far they can move around and let them describe it." – Individual

A few noted that decisions made about entitlement to ADP, specifically the 20-metre criteria, impact the receipt of other benefits. This includes disrupted access to the Accessible Vehicles and Equipment Scheme and termination of receipt of the blue badge benefit.

Other themes

In addition to the overarching themes, several respondents provided specific considerations or suggestions to include in the criteria. Some argued input from GPs, carers or other healthcare providers should be included in the decision-making process. Other suggestions each made by a few respondents are detailed in Appendix C.

Agreement with the existing criteria was expressed by some. This included support for the clarity of the new criteria as well as support for the current distance measures.

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

Among the three quarters who answered Q5a, many highlighted the positive impacts of the changes they suggested in Q5, while others noted groups they believed would be positively impacted. Not all respondents answered both parts of the question.

Positive impacts of suggested improvements

Several suggested that the changes would improve ADP clients' circumstances. This was most often related to receiving awards, but a few also suggested it would improve independence among clients. One individual mentioned it would allow clients to access help sooner, such as paid support, and another thought it would stop discouraging clients from exercising to improve physical and mental wellbeing.

The outcome of improved treatment of clients was highlighted in several responses. This included a view that clients would be treated with dignity, empathy, compassion and respect. A few felt that the improvements would create a less stressful application process.

Some noted their recommendations would benefit family and carers of disabled people, the larger community and society. Two individuals felt that improved decisions would put less pressure on their family and carers. Inclusion Scotland and the Neurological Alliance of Scotland suggested it would allow people to lead more independent lives.

"As a consequence more would find it easier to participate in family, social, community and economic life - including work. This would assist disabled people in living healthier, more fulfilling lives and assist our society in achieving greater equality and in reducing disabled people's economic inactivity." – Inclusion Scotland

Positive impact on different groups

Several believed their recommended changes would positively impact those with fluctuating conditions as the decision-making process would be more inclusive, holistic and nuanced. This would allow clients with fluctuating conditions to explain their situation more thoroughly and lead to more successful awards.

People who have Crohn's and Colitis, Multiple Sclerosis, fibromyalgia, chronic pain, and Parkinson's Disease were each mentioned by a few as groups who would benefit. A small number of other respondents also referenced hidden disabilities but did not specify which.

Some respondents noted that people with mental health conditions would benefit from the suggested changes due to either improved decision-making or broader criteria that took mental health into consideration.

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

Half of respondents answered Q5b. The most common theme was comments that the suggested changes would have no negative impacts to clients. Respondents making this point did not provide further details.

However, several respondents noted the suggested changes could have a negative impact on the Scottish Government's budget. Some believed this would be due to increased cost as more clients would receive higher awards. Some others suggested the increased costs would be due to the additional workload needed to implement a more nuanced decision-making process.

A few highlighted that case managers could make poor decisions due to more open or subjective decision-making processes. Scotland Versus Arthritis suggested this could be mitigated, however, by outlining questions in more detail and including prompts as to the types of supporting information needed. CPAG in Scotland noted that alterations to criteria may benefit some but disadvantage others as some who had received higher awards under previous criteria may receive less, and vice versa.

MS Society Scotland's Survey Tool Responses

The MS Society Scotland tool asked the question: 'If you could change or remove the 20m rule, what would you do?' While this most closely aligns with Q5, it differs by prompting respondents specifically about the 20-metre criteria. Almost all respondents answered this question.

The most common theme in response to this question was that the '20-metre rule' should be abolished. A few respondents suggested that it should be changed. Other responses matched the themes and prevalence of responses received via Citizen Space. The only difference was that more respondents answering via the survey tool highlighted the need to gather supporting information from GPs, carers, family members or other health professionals.

In place of Q5a, the tool asked: 'Who do you think would benefit from getting rid of the 20m rule?' Almost all respondents answered this question. The most common response noted that those with fluctuating and variable conditions would benefit most. The second most common these stated generally that applicants and clients of ADP would benefit. Many stated that people with MS would benefit from changes to the 20-metre criteria.



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