Disability assistance in Scotland: response to consultation

Our response to the consultation analysis report about the consultation on disability assistance undertaken between 5 March and 28 May 2019.

5. Section 4 - Disability Assistance for Older People (DAOP)

Section 4 of the consultation focused on Disability payments for older people. Currently DWP deliver Attendance Allowance for people age 65 and over. As is discussed above in section 3, the consultation set out the Scottish Government’s intention to align the entitlement age for Disability Assistance for Older People with the qualifying age for state pension.

5.1 Policy Proposal – Disability Assistance for Older People (DAOP)

We know that for older people, accessing Attendance Allowance can be challenging and that often it is the children of older adults, or their partners, supporting completion of the form on their behalf. We have undertaken significant user research through a discovery process to understand concerns about the current process and to ensure that, when Disability Assistance for Older People commences, the application process is much simpler, transparent and more accessible.

The consultation document sought views on aligning the age entitlement for this benefit with the state pension age. We sought views on the intention to deliver broadly similar eligibility criteria for DAOP to Attendance Allowance currently delivered by DWP. The consultation paper set out examples of when the different rates would be payable.

Respondent Feedback

A majority of respondents were content with our proposals to align payments for older people with state pension age and broadly follow the eligibility criteria for Attendance Allowance.

A sentiment provided in various areas across the consultation responses was that some respondents felt that there should only be one form of Disability payment for adults and that older people do not necessarily have different needs from people of working age. Feedback about the lack of a mobility component for older people was an example given by some respondents.

Scottish Government Response

The main purpose of DAOP (and Attendance Allowance) is to provide financial assistance to mitigate some of the increased costs associated with care needs that disabled people may have because of a disability or long-term condition. However, whilst a small minority of responses suggested that a mobility component should be included, like that included with DACYP or DAWAP, we believe that there are several important reasons why this would be unachievable to deliver.

Our analysis suggests that the impact of introducing a mobility component for DAOP that is similar to the mobility components currently provided for DLA and for PIP could be around an additional £580 million annually. This cost would increase annually and, with an increasing population, is likely to grow substantially in coming years, making the cost substantially greater.

The projected caseload and annual expenditure on AA (and its replacement benefit DAOP) is forecast to grow over the next five years.

Figure 1: Projected expenditure (millions) for Disability Assistance for Older People (2020/21 – 2024/25)[1]

Figure 1: Projected expenditure (millions) for Disability Assistance for Older People (2020/21 – 2024/25)[1]

Against this background, our estimate of the impact on caseload and the associated costs are set out in the tables below.

Table 1: Estimated caseload – new and existing DAOP clients eligible for mobility component (2020/21)

Total number of existing clients who would receive a mobility award 120,000
Total number of new clients who would receive a mobility award 70,000
Total number of all clients who would receive a mobility award 190,000

Table 2: Estimated annual expenditure – new and existing DAOP clients eligible for mobility component (2020/21)

Cost of mobility payments to existing clients per year £370m
Cost of mobility payments to new clients per year £210m
Total cost of mobility payments per year £580m

These forecasts are based on the forecasted DAOP client group in 2020/21. The DAOP caseload is expected to rise after this date (primarily due to demographic changes – with an ageing population, it is likely that the caseload will rise accordingly), so future costs could be higher.

Introducing a mobility component would mean that some disabled people in Scotland already in receipt of AA would not be eligible for the mobility component until their case transfers from DWP to Social Security Scotland, whilst other people in Scotland claiming DAOP may be eligible. This would cause unfairness, confusion and disruption for clients by creating a two-tier benefits system, with two different sets of eligibility criteria and rules, whilst undertaking a significantly complicated transfer process. It would also make delivering the benefit more complex, and would likely delay delivery of DAOP.

Under current DWP administration, clients in receipt of disability benefits may be entitled to additional 'passported' benefits and DWP premiums where the disability benefit acts as a 'passport' to automatic entitlement of additional benefits or premiums. If we were to introduce a mobility component to Disability Assistance for Older People, or a “whole life” benefit, DWP may not pay these reserved premiums or benefits.

There is also a risk that, should eligibility rules diverge significantly from current DWP rules, Disability Assistance may not continue to be recognised as 'like for like' for passporting purposes. This would put all reserved passported benefits at risk for clients eligible for Disability Assistance. We know that these passported benefits are very important to disabled people entitled to Disability Assistance.



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