Disability and Carer Benefits Expert Advisory Group – digital portal: response from ministers

Letter to the Disability and Carers Benefits Expert Advisory Group on 13 November 2019.

Digital portal development

Thank you for your letter of 27 September, and apologies for the delay in responding.

I am very pleased to hear that you found the meeting with Programme officials on development of the digital portal to be useful. I understand that you have since met officials working on the design and delivery of the assessments service, and hope that this was also helpful for the group.

You raised a number of specific points in your letter, to which I have responded below.

Involvement of people with lived experience 

I was pleased to hear that our work to involve people with lived experience of the current system was well-received by the group. As you are aware, this is at the heart of our service design approach: we have involved users (including existing recipients of Disability Living Allowance and those who support them) at every stage – indeed, virtually in every “sprint” – since we started work on the digital portal, and will continue to do so. 

This applies also to plans for staff recruitment and training, where I agree wholeheartedly with your recommendation that we and Social Security Scotland colleagues should draw on the expertise of people directly affected by these benefits, and those who support them. 

To help remove barriers for those applying for roles with Social Security Scotland and to encourage applications from those with lived experience, we have put in place a number of measures. We have removed the mandatory requirement for qualifications for entry level positions, ensuring that more people can apply for roles with the agency. Where appropriate for higher-grade posts, we accept relevant experience instead of qualifications. We are also making it clearer in our candidate communications that the examples used in applications and interviews do not need to be work-based. Social Security Scotland will accept examples from personal life, volunteering, sports clubs or education which allows candidates to demonstrate their lived experience.

As described at the session, we will adopt a scenario-based learning approach for agency staff, built upon "real" case studies and augmented by input from our user experience panels, so that training can give a holistic and wide-ranging view of clients’ experience of accessing social security support. 

We have already begun engaging with organisations such as Inclusion Scotland and Glasgow Disability Alliance to draw on their experience in this area (as well as benefiting from the expertise of your own members), and will continue to reach out to organisations as we move closer to delivery of the disability and carer benefits. 

Process for updates to systems in light of user feedback

You asked for more information about the process being developed to make changes to our systems in response to user feedback, and particularly about whether these processes will have the capacity to respond to high volumes of suggestions or issues. 

Once the benefits are launched to the public, they will become part of Social Security Scotland’s live running service. This includes a continuous improvement function which collates all forms of feedback (whether positive or negative) to inform priorities for future development and/or proposed changes to the process or policy. At present Social Security Scotland can easily record all feedback received from clients to ensure that we continuously learn from it; our IT systems allow this information to be collated, and plans are in place to increase resource in this area as we take over responsibility for disability benefits, to ensure that we retain capacity to act on client feedback.

Interaction of systems design with policy objectives

I agree with the point that you raise on the need for programme development to follow and adapt to policy objectives, and this is very much the approach we are pursuing.

Colleagues in both Policy and Programme divisions have regular, ongoing and substantive engagement to ensure that policy objectives, and supporting regulations, are encapsulated in our approach to service design. Where changes to service design are required as a result of changes to policy, early discussions take place to ensure that we understand the impacts of the proposed changes, and colleagues across the Directorate work towards achieving those shared objectives.

In relation to the disability and carer benefits, and the digital portal in particular, I can reassure your group that the systems involved (including the application forms and case management system) are being developed in such a way that they can be improved and amended in future to accommodate new policy directions or changes to processes. Once launched, the systems that we are currently creating through the Programme will be maintained by Social Security Scotland’s in-house IT function, who will implement any amendments required.

It is worth noting that, in the fast-paced delivery environment in which we are operating, and particularly pending completion of case transfer from the Department for Work and Pensions to Social Security Scotland, it is inevitable that there will be limits to what we can build and deliver operationally in the time available. It is pragmatic for the Scottish Government’s policy approach to social security to take some cognisance of this, as well as the financial context of this work. However, as I set out above, we are “future proofing” our systems design so that it is sufficiently flexible to accommodate, rather than constrain, the policy choices that a future Government may wish to make over the longer-term, once the devolution of powers is complete.

Supporting information

In your letter you raised several points in relation to information gathering, including information relating to medication and how we will evaluate the success of our approach to this.

I am pleased that you welcomed our broad approach to information gathering, which is based on your recommendations, in particular the balance of self-assessment supported by only one source of formal information in the majority of cases and that there will no longer be a hierarchy of supporting information. . I agree that it will be important to evaluate how well this is working in practice. As part of our commitment to continuous improvement there will be robust quality assurance built into the information gathering process from day one, and the decision making process will be monitored to consider what impact supporting information from formal sources is having on entitlement decisions. In addition, we will have the opportunity to build some management information into the systems which will help to identify whether we are achieving our objectives, particularly in relation to Disability Assistance for Working Age People where it will help us to monitor whether Social Security Scotland is achieving its aim of relying where possible on supporting information rather than face-to-face assessments.

In relation to your specific point about medicine labels, the example raised at the meeting (scanning medicine labels with a smartphone) was intended to illustrate the approach we take to exploring whether new designs or technologies could help make the application process easier. In this instance, we decided that the idea was not effective or feasible, so we have not taken it forward. Information about medications and treatments is part of the application form, and is intended to assist clients to describe accurately the impact of their condition(s) on them; but we recognise that in practice it is just one aspect of a person’s application, which a Case Manager will carefully consider alongside other aspects as part of our person-centred approach to decision making.

We understand the importance of providing clients with clear guidance as to the entitlement criteria, and ensuring they understand the types of information that Case Managers need to make entitlement decisions. We will seek stakeholder input on guidance for both Case Managers and clients, and all guidance will undergo user testing.

Date of claim where there are questions over residency/nationality

You asked about when the date of claim would be fixed, in cases where there are complexities around an applicant’s residency or nationality. I can confirm that, as you suggest, the date of claim will be established for the disability benefits at the point where the application is registered, with any further investigations taking place thereafter. This will be made clear to applicants within the form.

Audio conversion

You asked whether the application portal will be available in a format which allows audio conversion for those who may need it. I can confirm that the portal will be accessible, including to users of assistive technologies such as screen readers and text-to-speech tools. Decision letters will also be available in other formats, including braille, large print, and audio.

I hope that the clarifications above will prove helpful to the group.

Thank you again for taking the time to visit the Programme and engaging so positively with our work on service design. We would be very happy to welcome group members back to our offices in the New Year if you feel that this would be helpful, to discuss further work on the portal and/or on assessments design. 
If you would be open to such further visits then the relevant Programme leads will be in touch with you shortly via the group Secretariat to suggest potential opportunities.

Thank you again for your interest in and support for delivery of the devolved disability and carer benefits, which is of great value to the Programme and the wider Social Security Directorate.

Your sincerely,

Alison Byrne
Deputy Director, Social Security Programme Management and Delivery Division

DCBEAG – digital portal: response from ministers
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