Devolved disability benefits: decision making evaluation

Executive Summary

Background

As part of the devolution of disability benefits, there have been a number of changes made to decision-making in order to improve people’s experience as a whole and reflect Scottish Government policy, ensuring it is underpinned by dignity, fairness, and respect.

A key focus of this approach is that decision-making takes a person-centred and trust-based approach. This approach is in line with the Social Model of Disability and involves making a decision which considers the individual’s needs based on what they tell decision makers about the barriers they face.

This evaluation examined how decision-making policy has been implemented and experienced in practice, and what impacts it has had on individuals and staff. There was a particular focus on certain aspects of decision-making, specifically: applications; consultations; review periods; and reviews.

This evaluation is part of a wider programme of work evaluating the policy impact of the devolution of disability benefits.

The evaluation largely covers the period between March 2024 to April 2025, and draws data from a number of sources including:

• Interviews and focus groups with clients and formal representatives
• Observations with Social Security Scotland staff
• Interviews with Social Security Scotland staff
• Social Security Scotland’s Annual Client Satisfaction Survey 2024-25
• Social Security Scotland’s Annual Client Panels Survey 2024
• Social Security Scotland Official Statistics for Child Disability Payment (CDP), Adult Disability Payment (ADP), and Pension Age Disability Payment (PADP)

Key Takeaways

This report aims to explore qualitatively how client experiences of the different policy areas underpinning decision-making can be used to evaluate the extent to which people’s experience of decision-making were in line with policy outcomes.

Through the evidence examined in the report, it becomes apparent that for the people who participated in this research, the policy cannot be separated completely from the experience of the operational side of decision-making, nor from the specific and personal circumstances of each individual. Clients often draw from operational and personal experiences to illustrate their experiences of the anticipated outcomes of the policy, and to illustrate the aspects of their experience that are most important to them. Relatedly, it should be kept in mind that the evidence presented throughout is based on people’s own understanding and interpretation of the policy and what that means for their unique experiences.

Overall, there is evidence that the policy principles of decisions being person-centred and trust-based are being met, however, client experience tended to vary depending on their circumstances.

Clients were more likely to feel that their experiences were in line with decision-making policy if:

• they had a successful application
• they had no decrease at review
• they had a scheduled review

Clients were less likely to feel that their experiences were in line with decision-making policy if:

• their application had been unsuccessful
• they did not agree with the award decision
• their award had been decreased after review
• they had an unscheduled review

The main themes that emerged from clients in relation to what led to decision-making feeling person-centred and trust-based were:

• feeling they were able to tell their story
• feeling heard
• feeling believed
• feeling trusted

Key mechanisms for the realisation of these themes were:

• decision letters
• contact, or opportunity to engage, with Social Security Scotland Staff

As above, separating client experience of decision-making policy specifically from other elements of their experience is complex, and therefore it is not possible from this research to ascertain whether all client experiences can be attributed to decision-making policy, or whether experiences are impacted by aspects such as:

• operational aspects
• individual circumstances and/or eligibility
• outcomes of applications/reviews

Findings

What is working well?

• Overall, there was both quantitative and qualitative evidence of positive experiences across many of the outcomes, including those for applications, reviews, review periods, and consultations. These were mostly experienced by clients who were successful applicants or who had an increase or no change in their review award.
• Decision letters positively impacted experiences of outcomes for successful applicants and those who received an increase or no change in their review award. These clients felt that the letters accurately reflected the impacts of their condition or situation and that the supporting information they had supplied was considered, citing approaches by Social Security Scotland staff as being person-centred and trust-based, and the right decision being made first time.
• Case Managers explained how they justified decisions by clarifying what information they had used and how they tailored letters to individual situations.
• Case Managers and other staff spoke about the importance of understanding the impacts of people’s conditions and demonstrated how they took this into account in their decision-making, using the decision-making tools to support them.
• Staff with experience of decision-making across all types of disability payments felt that the application forms for CDP and PADP particularly, allowed for person-centred decision-making because the questions are open.
• A key positive factor for clients was the opportunity to have direct interaction with Social Security Scotland staff during the application or review process where they felt that they were able to explain their condition or situation. Again, this was mainly for successful applicants or those who received an increase or no change in their review award.
• Largely, for those who had had a consultation, it was experienced positively. These clients described experiencing a trust-based approach from understanding and caring Practitioners who listened to them. These clients also accepted the need for a consultation and felt positive about the outcome of it.
• Among staff, there was consensus that consultations are used in line with guidance, e.g. where it has not been possible to make a decision using other tools. Staff felt that consultations take a person-centred and trust-based approach, that they are used only to seek further information that is necessary to make a decision rather than to scrutinise existing information.
• Clients who had no changes to their circumstances and, especially those who had an increase or no change to their review award, reported positive experiences of the review outcomes as well as feeling that their experiences were in line with dignity, fairness, and respect. These clients tended to describe the review process as easy and straightforward, and to accept the need for a review. Some of these clients also cited the review form as being easy to complete and therefore mitigating against stress.
• Clients who reported changes to their circumstances had some positive experiences of the outcomes. Many clients are aware of their responsibilities and are proactively reporting changes to their circumstances. Some clients mentioned the decision letter as well as other contact with Social Security Scotland as the mechanism for making it clear that they had to report changes of circumstances.
• Case Managers described their approach to reviews in line with the policy in that they only sought supporting information if clients reported a new condition, or when previous information was outdated or did not reflect the client’s current condition. They also felt that this would mitigate against undue worry or stress to clients.
• Some clients reported positive experiences of review period outcomes. These clients felt that they understood the reasoning provided for the review period and that the review period reflected their circumstances or needs. These clients also tended to feel that the review period was appropriate for them. Some of these clients also felt that review periods positively impacted their ability to plan ahead financially.

What are the challenges?

• Negative experiences tended to be indicated or raised by both survey and focus group/interview clients who were unsuccessful applicants or who had received a decrease in their review award. This was consistent across the vast majority of outcomes.
• Many of these clients felt that decision letters were a key factor as to why their experience was not in line with several of the outcomes, including, person-centred, trust-based or that the right decision had been made first time. Several of these clients felt that the decision letter did not reflect their situation accurately or fully capture their situation. Some of these clients also felt the supporting information they provided was not being taken into account, or that it was not gathered from all professionals listed in the application.
• Some of these clients felt they were not able to fully explain their situation or condition at application or review and would have liked an opportunity to directly do so to Social Security Scotland staff. This was particularly the case for unsuccessful applicants or those who had received a reduction in their review award, and those with complex or fluctuating conditions, and was exacerbated by certain situations, for example, for those who reported a change to their circumstances. Survey data indicates that this is especially the case for those with social and behavioural conditions.
• Clients who felt their experience was not trust-based also discussed factors outwith decision-making policy, highlighting a lack of knowledge of how to answer the questions appropriately in review and application forms.
• Staff with experience of decision-making across all types of disability payments felt that decision-making was more person-centred for CDP and PADP than for ADP. This was attributed to the openness of questions on application forms for CDP and PADP. However, CDP and PADP Case Managers also mentioned having to call clients more to clarify information when they did not include the right amount of information for them to make an informed decision, attributing this to the openness of the forms.
• Some Case Managers highlighted the difficulty in using decision-making tools to focus on impacts in cases where there is conflicting information. Some expressed difficulty navigating the balance of probabilities, where individuals’ particular situations were lacking precedence in the decision-making guidance or where there was limited information available to them. Some also demonstrated the difficulty in not using their prior knowledge about conditions to help them make decisions.
• Clients were generally uncertain on whether they had had a consultation. There was evidence that clients had mistaken more informal phone calls from Social Security Scotland staff as consultations.
• Some clients were unsure of why their review period had been set or how it reflected their circumstances or needs, and some felt that the reasoning given in decision letters on review periods could be clearer. These clients were less likely to agree that the review period was appropriate for them.
• Unscheduled review clients who reported changes to their circumstances were more likely to report negative experiences of the outcomes. Many of these seemed to stem from lack of understanding. These clients were less likely to think the process was clear, to understand their responsibility to report a change of circumstances, and to understand what they should report specifically when reporting a change of circumstances. On the latter point, the same was true for some scheduled review clients who did not have a change of circumstances, where they expressed a lack of clarity on what to report.
• Some ADP and PADP Case Managers felt that setting review periods could be complex because of treatment cycles and fluctuating conditions.
• Outwith the policy impact, many clients mentioned lack of application progress updates and processing timescales as factors that negatively impacted them understanding what is happening and why at each stage of the process. Furthermore, change of circumstances clients were more likely to express the time taken to process the review as a burden.
• There was some evidence across the data of a wider misunderstanding of whether decisions are focussed on conditions or the impacts of that condition, where some ADP clients felt that the points-based system is condition focussed.
• Case Managers and Practitioners felt that the open-ended options on the review forms where changes of circumstances have been reported, as well as limited supporting information from the first decision, could lead to clients giving too little information, increasing the need for them to seek further supporting information.
• The outcome of individuals understanding that disability benefits, where entitled, is a human right was largely not achieved, with clients across all the outcome groups showing either mixed understandings or beliefs (successful applicants/ increase or no change in review award clients) or feelings that their experience did not align with this (unsuccessful applicants/ decrease in review award clients).

Considerations for policy and practice

The considerations discussed in this section have been identified from looking across the challenges described in the progress towards the short-, medium- and long-term outcomes. They also align with those identified in the commissioned qualitative research, building on these with evidence from other sources.

1. It is clear from the findings that decision letters are important to clients’ experiences. In order to maximise the likelihood that the policy outcomes are met, all decision letters regardless of the decision should therefore consistently:

• show clients that, regardless of the decision, they are believed and that the impacts of their condition have been heard and recognised,
• balance the above with a detailed justification of why and how the impacts of their condition do or do not meet the criteria,
• demonstrate to clients that their situation or condition and its relevant impacts have been fully considered, drawing on the application form and explaining how and why different supporting information was gathered and used to inform the decision, and
• justify review periods in relation to the client’s condition or situation and its impacts as well as in relation to when these are likely to change. This will allow clients to feel that they can plan financially and mitigate against financial-related stress.

2. There is a strong desire among clients to have direct communication with Social Security Scotland in order to explain their situation or condition and the impacts more fully, at application, review, and for changes of circumstances.

3. The consultation process should be clearer to clients. There is a lack of awareness for individuals as to whether they have had one, and a perceived lack of clarity around the circumstances in which clients can request and have one.

4. There should be some consideration to the differences between the application and review processes across the disability benefits with regard to how each allows clients to fully express their situation or condition and its impacts.

5. There is a need for further clarity to clients regarding how decisions are made in relation to conditions vs. the related needs. For example: more information upfront about how decisions are made against the eligibility criteria; and more guidance on what to report for a change of circumstances, specifically with reference to conditions and impacts.

6. Case Managers desire more guidance and support to aid in their decision-making. This could take the form of more collaborative working with Practitioners, alongside improvements to the decision-making guidance to include more examples of scenarios.

7. External factors such as application updates, processing timescales, and the points-based system have a significant impact on clients’ experiences of these outcomes and therefore should be considered in tandem to any policy-related improvements.