Independent Review of Adult Disability Payment: final report - summary

Chapter 3: A Learning System

Throughout the course of my review, I saw that there is genuine intent from Scottish Government and Social Security Scotland colleagues to listen to feedback, embed the learning and adapt policy and practice whilst acknowledging that there is still some way to go to realise all the ambitions set out in the Charter.

I have experienced the Social Security Scotland quality assurance process and have seen evidence of both staff and stakeholder feedback leading to improvements, as well as a “feedback loop” between Social Security Scotland and the Scottish Government.

Some of the most common complaints I heard during the Review related to communications and problems with the systems used by Social Security Scotland.

Communication

Despite the lack of proactive communication being a recurring theme within the consultation, most clients felt that they received the information they needed from Social Security Scotland. Respondents also reported long wait times for decisions and the telephone helpline, as well as staff being unable to provide adequate progress updates. Social Security Scotland have said it is aiming to improve communications with people applying for benefits.

Social Security Scotland has recently stood down its Inclusive Communication External Stakeholder Reference Group, which was created to help provide expert advice and to assist with meeting legal and organisational commitments regarding inclusive communication. The membership of this Group has been incorporated into the Operational Reference Group.

I heard consistently throughout the course of the Review that clear and accessible communication to clients at the outset, with a named point of contact would improve trust and efficiency. I believe that having a more personalised and accessible route to two-way communication throughout the application and re-determination process is worthy of consideration. Consultation responses also highlighted the importance of accessibility, language preferences and a person’s preferred method of communication being adhered to, as failure to do this can undermine people’s agency and worsen the impact of delays.

I asked disabled people what could be changed about communicating the decision outcome and although nothing specific was suggested, there was a general feeling that more personally tailored communication could help clients clearly understand the decision.

"The award letter explained perfectly why I received points for each section and although it was really upsetting and quite shocking to read that back about myself and realise the seriousness of my conditions, I felt that they did it with understanding, compassion and most importantly respect. Something I never received from PIP.”

- Individual response to the Independent Review of Adult Disability Payment Consultation

I heard from some stakeholders that decision letters were too long and information about appeals and re-determinations should be more prominent. Others felt that the current decision letters make it much easier to form the basis of a re-determination request or appeal. I was also told by stakeholders that “cut and paste” is sometimes being used in shorter and less detailed decision letters, making it harder for clients to understand their decision. Stakeholders welcomed the introduction of translated decision letters but felt that more languages should be added to ensure the needs of minority communities are better met.

Whilst SRTI is outside the scope of my review, individuals with terminal illnesses told me that they do not see themselves reflected in communications. I believe that more inclusive language is needed to ensure these individuals feel adequately represented and I would hope that Social Security Scotland always ensures their communications are considerate. One Advisory Group member suggested that highlighting the relatively low uptake of the SRTI provision in publicity materials and on the Social Security Scotland website might act as an incentive to improve communications and messaging to people with a terminal illness and to professionals involved in their care.

Social Security Scotland said in its response to my interim report:

"Social Security Scotland will continue to work with stakeholders, including relevant organisations in the third sector, to highlight that Adult Disability Payment is available to terminally ill people and the existence of the special route for applications. Social Security Scotland currently specifies that Adult Disability Payment is for disabled people, people with long-term health conditions and people who are terminally ill in communications where possible and will continue to ensure the use of appropriate language in these communications.”

- Social Security Scotland, Response to Interim Report of the Independent Review of Adult Disability Payment

Some of the other communication issues disabled people and stakeholders raised with me during the Review included:

• reasonable adjustments being common in many processes concerned with public services and yet no reasonable adjustments are used or promoted in the application process for Adult Disability Payment
• some suggestions that a “don’t panic, it’s going to be ok” type of reassurance be noted in correspondence, particularly in relation to the application form
• Social Security Scotland staff not responding to access or communication needs – welfare rights advisers are continuing to highlight the impact of failure to ensure that a person’s appropriate communication methods are being used at all points in the journey
• unsolicited telephone calls in an attempt to fill gaps in information continue to cause distress and confusion.

I believe that there is a need for communication methods that do not require engagement in “real-time” to accommodate individuals with fluctuating energy levels, or the use of video calls in situations where real-time communication is essential.

I heard requests from LGBT+ disabled people and stakeholder organisations for all client-facing Social Security Scotland staff to adopt LGBT+ friendly language, for pronouns to be accepted and the use of wording that respects a person’s expression of gender identity. This includes developing administration systems that can easily change the name, title and gender on a person’s record.

Observation 4:

I recognise that changing communications addressed to clients using a name other than their legal name could have implications for accessing passported benefits or entitlements. However, providing individuals with a service that aligns with values of fairness, dignity and respect should mean that people are addressed in a way that aligns with their expectations and preferences.

I am mindful that there is an option to capture someone’s preferred name if they contact Social Security Scotland by telephone.

I am aware that Social Security Scotland currently offers email notifications for some non-statutory client correspondence; however, there are continued client requests for more digital communication options. I understand that a transition to fully digital client communications is not possible due to data protection laws, considering the needs of a variety of audiences, work is ongoing with Social Security Scotland and the Scottish Government, to look at how this might be achieved in the future.

Overall, my findings show that accessible and appropriate communication with individuals applying for Adult Disability Payment should be combined with a consistent approach to providing information to authorised representatives and the provision of escalation routes capable of improving efficient responses to problems that may arise.

Recommendation 35:

Social Security Scotland to consider updating the suite of guidance available to clients to ensure information is always available in Braille, BSL, Easy Read, other commonly used languages and other accessible formats.

Recommendation 36:

Social Security Scotland to review its inclusive communication practices with a view to ensuring there are no barriers to people with communication needs applying for Adult Disability Payment.

Recommendation 37:

To consider providing a point of contact to improve trust and ensure a more personalised and accessible route to two-way communication throughout the application and re-determination process.

Recommendation 38:

For Social Security Scotland to set out whether it intends to highlight and make more prominent the option to request written translations of determination and re-determinations letters to ensure the needs of minority communities are better met.

Recommendation 39:

For Scottish Government and Social Security Scotland to build capacity for policy makers and front-line staff to undertake training on stigma particularly as it relates to for example, poverty, inequality, race, and gender identity.