Independent Review of Adult Disability Payment: final report

A People’s Service

The client voice

Throughout the Review I saw how both the Scottish Government and Social Security Scotland are working hard to ensure that people with lived experience of Adult Disability Payment are involved in all matters from policy setting to accessible communications. There is evidence of the learning from the Client Panels and Client Surveys being incorporated to improve customer service and during the early years of the establishment of Social Security Scotland there is evidence that demonstrates a commitment to listening to the experiences of disabled people. However, for Adult Disability Payment applicant respondents to the Client Survey, overall ratings of experience with Social Security Scotland decreased from 85% in 2022-23 to 75% in 2023-24 (the number of these respondents increased from 4,790 to 11,808). For Adult Disability Payment case transfer respondents overall ratings of experience increased from 82% to 85% (again, the number of respondents increased from 2,704 to 9,231).^[48]

During the establishment of devolved social security powers in Scotland, many of the decisions taken in relation to the policy and delivery of disability benefits were informed by external input, in particular the Disability and Carers Benefits Expert Advisory Group (DACBEAG).

DACBEAG operated from 2017 to 2023 to provide recommendations and advice to Scottish Ministers, by request and proactively, on the policy and practice options under development by officials on disability benefits. The Group’s membership consisted of individuals working for significant stakeholders across the Scottish landscape, including The ALLIANCE, Child Poverty Action Group in Scotland, Inclusion Scotland and Glasgow Disability Alliance.

The Scottish Government established the Ill Health and Disability Benefits Stakeholder Reference Group (IHDBSRG) in 2016, and it is still active. Scottish Government officials chair the Group, and the Group provides advice directly to them (unlike DACBEAG). Membership of the Group includes representatives from across the stakeholder landscape and the remit of the Group is to provide advice on:

• the evidence-base for policy decisions
• potential impact of policy decisions
• user and stakeholder engagement
• fit with the wider public sector landscape
• interaction with wider Scottish and UK social security benefits.

In addition, the Social Security Experience Panels operated from 2017 to 2024. Members of the Panels had experience of at least one of the benefits delivered by the DWP that transferred to Scotland. Over 2,400 people registered to take part in the Experience Panels^[49]. As Social Security Scotland is now operational and most benefits are live, the Experience Panels closed in March 2024. Client Panels are a significant legacy of the Experience Panels and will ensure people with lived experience remain at the heart of the delivery of social security in Scotland. Social Security Scotland launched Client Panels in 2020 in recognition of the need for engaging people with lived experience for ongoing development and improvement of Social Security Scotland. Client Panel members are recruited from current clients of Social Security Scotland.

Social Security Scotland Client Panels include Social Security Scotland clients from across Scotland. Social and user researchers invite Client Panel members to take part in research to inform improvements to Social Security Scotland’s service, involving surveys, interviews and focus groups with participants. Research has informed a range of operational decisions, including letters, SMS updates, and updates to the Charter. There is also a programme of Scottish Government evaluation of the devolved benefits,^[50]which includes the Scottish Government’s supporting information evaluation.[51]

Client panels are not the only route for client input. Social Security Scotland also have the Client Survey and other client feedback, including complaints, on which official statistics are published annually. Social Security Scotland also undertakes user research on specific topics, to understand client's experiences and to test new ideas and designs.

Social Security Scotland has integrated the membership of the Inclusive Communication External Stakeholder Reference Group into its Operational Reference Group.

The Operational Reference Group brings together a range of experts and practitioners to provide advice to Social Security Scotland on how it delivers its services. The remit of the Group is to:

• provide advice on the design and delivery of Social Security Scotland’s service
• support Social Security Scotland’s continuous improvement by providing stakeholder insight on what is going well and areas for improvement
• provide advice and support for Social Security Scotland’s communication and engagement with clients and stakeholders - this will include operational updates and information about new benefits
• advise Social Security Scotland on the development of effective partnership arrangements that will enable it to increase the level of support it can provide its clients.

And yet, despite all this engagement and consultation some disabled people and stakeholder organisations either don’t feel heard or they fear that little or no change will come about because of their engagement. I was frequently told that people and organisations are growing tired of repeated conversations with little evident change to the system which damages trust and results in disengagement. We need to continue to be conscious of the consultation fatigue experienced by some people with lived experience and those from third sector organisations. Some seldom-heard groups have a distrust of the state and in some meetings, it was necessary for me to stress repeatedly the independence of the Review.

Recommendation 1 : The reinstatement of an expert by experience group to guide the next stage of the evolution of Adult Disability Payment following the publication of this report.

Raising awareness of Adult Disability Payment and encouraging applications

Disability benefits are an essential source of income for many disabled people in Scotland. They provide vital financial support to cover the extra living costs that arise from living with a disability or long-term condition. Disabled people in the UK tend to have lower incomes and lower wellbeing than the average person/household.^[52] Not only are disabled people facing more financial difficulty overall, but they report a lower quality of life.[53]

Receiving disability benefits significantly enhances the life satisfaction of recipients, potentially reducing their anxiety levels and improving their wellbeing overall. The observed increase in life satisfaction among disability benefit recipients suggests that these benefits mean more than a simple cash transfer to those who receive them.^[54]

Given the significant potential boost in wellbeing after receiving disability benefits, it is necessary to explore why someone who is eligible might not be receiving them. While the specific reasons why some individuals may not be applying for Adult Disability Payment can be difficult to pinpoint from my findings, it is evident that more could be done to address the most common reasons cited.

Discussions with stakeholders suggested that there may be many factors that influence the take-up of disability benefits. Some factors suggested are:

• the awareness of Adult Disability Payment itself is limited, and individuals may be unaware of their eligibility and the process to make an application
• the perceived stigma associated with applying for disability benefits; this included stigma from within close social and familial circles to the perceived national discourse about benefit recipients being viewed as ‘work-shy’ and ‘scroungers’; it can be a particular issue in some minority ethnic communities
• the application process itself or fear of rejection deters some people from applying; existing evidence (which includes PIP cases as well as Adult Disability Payment applications) on how difficult people find the process, and the number of rejected applications, suggests these are common barriers to people receiving benefits that they are eligible for.^[55] Social Security Scotland data shows that 42,855 re-determinations have been requested by new applicants for Adult Disability Payment; of the re-determinations that have been completed by 30 April 2025, 51% resulted in a change to the decision in favour of the client[56]
• while I generally have had positive feedback on the differences between Adult Disability Payment and Personal Independent Payment, there is still difficulty in believing that the systems are materially different
• the process of obtaining Adult Disability Payment is often complex and challenging, potentially exacerbating the already heightened anxiety levels experienced by disabled people; this difficulty can negatively impact people’s mental health and overall wellbeing, creating a vicious cycle as mental health problems are increasingly becoming the primary reason in the UK for applying for disability benefits in the first place.^[57]
• stigma associated with mental health problems also acts as a barrier for some people which can be a particular issue for some minority ethnic communities where stigmatising language and harmful stereotypes of mental health problems can be prevalent
• eligible people believing that Adult Disability Payment is only for people with a physical health condition
• people not applying because they view public resources as scarce in supply and other people as ‘more eligible’ for support
• people who are eligible not applying because they are unaware that the benefit is not means tested.

There are studies which have corroborated these stakeholder insights. A Joseph Rowntree Foundation study exploring how social security can deliver for disabled people in Scotland concluded that a benefits system ‘littered with add-ons and extras’ was experienced by disabled people as ‘confusing, exhausting and inefficient’.^[58]

Another study, a systematic review carried out by Public Health Scotland, looked at the impact of UK welfare reform in 2024,^[59] also found that UK welfare reform was associated with a worsening in mental health outcomes for those affected, with no evidence of an improvement in physical health.

Stakeholders frequently raised the legacy of PIP. Some people describe their experience of engaging with DWP as ‘traumatic.’ I also heard that people were not aware of the differences between Adult Disability Payment and PIP. One stakeholder suggested that Social Security Scotland needs to engage more with disabled people to try and improve the awareness of these differences.

In the case of devolved benefits, there are concerns from stakeholders that the requirement to interact with two systems (Social Security Scotland and the DWP) creates further complexity and additional barriers to take-up among some groups. In evidence given to the Scottish Parliament’s former Social Security Committee in 2021, the Council for Ethnic Minority Voluntary Organisations Scotland noted the concern that ‘people will lose out on benefit entitlements due to the increasingly confused welfare benefits landscape’ created by the parallel reserved and devolved system.^[60]

“It impacts my mental health as it focussed on the things I can no longer do. I had to appeal to get the right level of support for the mobility component. It's soul destroying having to relive all the trauma that you go through getting a diagnosis of MS. Nothing is ever going to improve as it's a progressive illness. Having to fill in the lengthy paperwork is mentally challenging and difficult to do.” – Quoted in MS Society Scotland response to the Independent Review of Adult Disability Payment Call for Evidence^[61]

“It was a very long and stressful process that I would not rush into again. I believe I should be entitled to a higher rate but the fear or having to go through it again has stopped me from applying for it.” – MS Society Scotland, response to the Independent Review of Adult Disability Payment Call for Evidence^[62]

A robust estimate of the eligible population for Adult Disability Payment cannot currently be made. This is because disability-related questions that are currently asked in surveys may not capture all of the eligibility criteria for disability benefits, and disability is self-reported in surveys which means perceptions of disability may vary person to person.

A further complication is that Social Security Scotland make person-centred decisions based on the specific circumstances of the application/review and detailed information provided. Therefore, it is not possible to match those identified as disabled through surveys with those determined to be eligible for disability benefits.

The Scottish Government has a take-up strategy which focuses on raising awareness of benefits and supporting access but does not currently focus on benefit-specific areas.^[63]

Robustly estimating eligibility and take-up for disability-related benefits is a significant challenge.

Revised estimates for general take-up, produced by Scottish Government analysts, were published in November 2024^[64] although there are no results for Adult Disability Payment.

It is not currently possible to estimate the take-up rate of Adult Disability Payment; this includes take-up estimates for Adult Disability Payment in seldom-heard groups.

Data on seldom-heard groups is not routinely collected by Social Security Scotland. Collecting this data would only provide an indication of the numbers of people from seldom-heard backgrounds who have engaged with Social Security Scotland, rather than providing the size of the eligible population.

Understanding the eligibility for Adult Disability Payment amongst seldom-heard groups at a population level would be additionally challenging, as the population of those who were seldom heard would need to be calculated from the overall eligible population.

Maximising benefit take-up among seldom-heard and vulnerable people is central to the Scottish Government’s take-up strategy.^[65] A stated aim of the Scottish Government is to increase inclusivity within the benefits system. This inclusivity incorporates a commitment to engage with seldom-heard groups and people with protected characteristics.

To further improve benefit take-up, the Scottish Government commissioned the Scottish Centre for Social Research (ScotCen) in 2023 to better its understanding of those groups furthest removed from the social security system and the particular barriers they face in accessing entitlements.^[66] The insights highlighted align with Scottish Government understanding of barriers and enablers to take-up, as reflected in the current Benefit Take-Up Strategy and Benefit Take-Up Principles.[67]

In addition, there was one evidence review, commissioned in 2023, conducted by ScotCen and published in May 2024, and one follow-on market research piece conducted by Social Security Scotland (to inform communications and marketing approaches), that were not published.

The Scottish Government, together with Social Security Scotland, is currently focused on responding to the research recommendations contained in the Seldom Heard Groups Evidence Review.^[68] This also includes responding to the recommendations from separate activity conducted in Spring 2024, via a Citizens Panel, to understand the impacts of stigma on benefit take-up.[69]

The findings from the research will support the Scottish Government in the implementation of its Benefit Take-up Strategy by providing information that will help develop new approaches to support people to access social security benefits. Social Security Scotland commissioned further research with a range of seldom-heard groups (including Gypsy Travellers, recently released prisoners, care experienced people and ethnic minority community members) to explore barriers, communication needs and effective messaging with the findings informing communication and engagement approaches.

Throughout the call for evidence, one organisational respondent noted that there was not enough available evidence or research detailing the experiences of uptake of social security benefits among Black and Minority Ethnic (BME) communities, noting this was also highlighted in the ScotCen research commissioned by the Scottish Government. While they cite Social Security Scotland’s client equality and diversity data release for June 2021 - March 2023, which would suggest Adult Disability Payment uptake for BME communities is lower than average, that data is complicated by the transfer of the payment from the DWP to Social Security Scotland during that period.

“Unfortunately, there is a significant lack of information on the experiences of Black minority ethnic (BME) people who are applying for [Adult Disability Payment], as well as on BME people with disabilities in Scotland and their access to benefits. We continue to highlight the issues with evidence in Scotland and advocate for better data collection by ethnicity, higher standards for public sector data, and proactive plans to fill these gaps in data and evidence. The lack of data severely limits the ability to implement effective policy and accurately evaluate its impact.” – Coalition for Racial Equality, response to the Independent Review of Adult Disability Payment Call for Evidence^[70]

There may be specific reasons why applications from people who identify as belonging to a minority community appear to be less successful in terms of receiving an award. Whilst these could stem from take-up barriers, I recognise the need for caution in equating refusal rates with take-up, because it is not currently possible to estimate take-up rates for disability benefits or for specific client groups.

“Those in seldom-heard groups have likely overcome many barriers in their lives already, so it is unlikely to be one particular barrier that prevents them from applying, but ‘barrier exhaustion’. They may have found it difficult to get information about benefits in the past; not known how to apply; needed support to apply but none was available; felt embarrassed or stigmatised; and are additionally already dealing with so much that they just don’t have the energy to fight for something they are entitled to.” – Age Scotland, response to the Independent Review of Adult Disability Payment Call for Evidence^[71]

Recommendation 2 : To further develop strategies to effectively engage with seldom-heard voices and individuals who may be eligible but do not apply due to stigma, to address the societal and sometimes cultural stigma associated with disability benefits to ensure broader and fairer access.

Recommendation 3 : Social Security Scotland should consider how effective its understanding is of take-up amongst seldom-heard groups and consider ways to maximise its reach.

Trauma-informed approach

For those accessing Adult Disability Payment, the decision-making and consultations can further add to the distress experienced.

A trauma-informed approach to practice aims to minimise the risk of causing trauma and to prevent re-traumatisation. The importance of this approach is reflected in government supported guidelines such as the roadmap launched by the National Trauma Transformation Programme in 2023.^[72]

During the Review people described experiences during their Adult Disability Payment journey that did not align with trauma-informed approach. For example:

“a lack of trauma informed practice was evident in all aspects of the process, including application, assessment, written and verbal communications.” - Premenstrual Dysphoric Disorder and the welfare state: Recommendations for reform^[73]

“When you are emotionally drained from what’s happening, filling out a booklet wanting to know how poorly your child is, it just adds to the emotional trauma you feel as a parent.” – Individual, The Cost of Waiting Report^[74]

When I met with a group of people who describe themselves as living with pandemic-disability (this includes people with Long Covid, people with vaccine injury, many of whom have Myalgic Encephalomyelitis (ME) and Chronic Fatigue Syndrome (CFS) , and people at high clinical risk of adverse consequences from re-infection) they stressed how helpful it would be for Social Security Scotland to be aware of the extent of trauma that many of them will have experienced.

Such experiences can set expectations for engaging with any official body. It is no exaggeration to say that for some people an appointment could re-traumatise them or cause trauma or Post-Traumatic Stress Disorder (PTSD) symptoms.

“Now I think the PTSD [post-traumatic stress disorder] is quite important, because I feel traumatised as a person going through what I go through every month and gone through it for so many years as well.” – Individual, quoted in Premenstrual Dysphoric Disorder and the welfare state: Recommendations for reform^[75]

For Social Security Scotland, this clearly has implications for how it delivers its services and trains case managers and practitioners^[76].

Recommendation 4 : In addition to the pilot underway within Social Security Scotland, ensure a trauma-informed approach is embedded in all aspects of its work, by producing a framework where trauma-informed principles are reflected in the practice of Social Security Scotland.

Accessing other relevant services

Beyond the realm of social security, people’s lives are interconnected, and they will often receive services from a range of agencies. It is important that these services complement each other and are joined up. Most people I spoke to during the Review felt strongly that social security for disabled people and its budget should remain distinct from other services,^[77] whilst ensuring that it sits as part of a wider package of support for disabled people.

In a country the size of Scotland it should be possible for the Scottish Government to use its reach to ensure everyone who makes an application for Adult Disability Payment (whether the application is successful or not) is signposted with their consent to the relevant local statutory or voluntary services that may be able to provide additional advice, support, and signposting.

In Australia, the National Disability Insurance Agency works formally in partnership with other government services that provide support to disabled people such as health, social care, education, justice and transport.^[78]

All areas work together so disabled people receive support to meet their individual needs. Access to mainstream services, community-based activities and other statutory services is a shared responsibility with the Agency and governments work together to resolve any issues where their services interact. Local area coordinators support communities and multiple levels of government to create a more inclusive society and deliver improved outcomes for all people with a disability. A person can ask their local area coordinator about the support available in the local community, even if they are not eligible for the Australian equivalent of Adult Disability Payment. Local area coordinators have strong connections in the community and can help connect with supports in a local area including community groups, recreational activities such as sporting clubs, performing arts groups and other social networks.^[79] The local area coordinator can also help a person to understand how a social security payment works with other government services and can connect to statutory agencies like education, health and transport.

Although it is unrealistic to replicate the Australian model in Scotland – indeed there are aspects of the model that I wouldn’t recommend, there are some aspects of it that, if introduced, would significantly enhance the quality of life of disabled people in Scotland and address some of the recurring themes concerning access and eligibility for complementary services.

There is an established model in Scotland for people with a learning disability. One example of this is ENABLE's local area coordination (LAC) service^[80] which aims to support every person who has a learning disability, as well as their families and carers - wherever and however they are needed.

LAC is a globally recognised approach to supporting people of all ages in local communities, and their families, in pursuit of their vision of a good life. LAC aims to be there for everyone regardless of their circumstances. You don't need a budget or a referral to access this service.

Coordinators do different things depending on what people want. Coordinators might:

• work with individuals, families and communities to make local activities and services more inclusive
• work with people who want them in their lives, go at a pace that suits them and stay involved for as long as they want their support
• focus on what people can do, rather than what they can't do – empowering them to live the life they choose.

Scotland has an established network of Third Sector Interfaces (TSIs). The TSIs are part of a wider network called TSI Scotland Network which is made up of 32 partnerships and ‘single door’ TSIs who work across communities of Scotland to support the third sector on the ground. Together they aim to support Scottish Government and influence critical thinking and future policy development for the third sector including charities, development trusts, community and voluntary groups, social enterprises and volunteering. Although the TSIs themselves do not provide a ‘one-stop shop’ type service they will have members in each local authority area who provide services, advice and other forms of support to disabled people.

Research undertaken by the Scottish Government^[81] exploring barriers to collaborations between third sector, local government, and national government. found that although TSIs have the potential to strengthen third sector capability and capacity, there were challenges which included:

• the short-term funding model acted as a barrier against collaborative working as did the general reduction in funding
• funding that is received by third sector organisations and local government is often inflexible, rigidly structured, and/or ring-fenced; this poses challenges for organisations to respond flexibly to meet the needs of service users
• third sector organisations, which felt that public sector-funded organisations did not trust them, which had an impact on funding for specified projects.

ALISS,^[82] ‘a local information service for Scotland’, created by The ALLIANCE is a website that can be used to find services, groups and activities for health and wellbeing across Scotland. ALISS contains information on more than 5,000 services from almost 3,000 organisations across Scotland.

The information is determined by postcode so it provides a comprehensive local hub of knowledge, services and support and can be accessed by disabled people and their families. A person can find food banks, addiction services, mental health support services, youth groups, money advice, social security advice, employability support and much more.

Getting it right for everyone (GIRFE) is a Scottish multi-agency approach to health, social work, and social care support and services from young adulthood to end of life care. GIRFE intends to shape the design and delivery of health and social care services, ensuring that people’s needs are met. It is about providing a more personalised way to access help and support when it is needed. The ambition of GIRFE is to place the person at the centre of all the decision-making that affects them, with a joined-up consistent approach regardless of the support needed at any stage of life.^[83]

During the GIRFE co-design process, people with lived experience expressed their sense that they often felt overwhelmed with the number of different people involved in their care and the number of different uncoordinated appointments that they were required to attend. People found the health and social care system very complex to navigate and it was often difficult to understand what services were available to them and how to access them. As a result, the pathfinder and partner teams co-designed the ‘co-ordinator’ role, which aims to provide people with a single point of contact from their multi-disciplinary team, who will provide a co-ordination role to ensure that their health and social care needs are understood and met.^[84] I appreciate that the focus for GIRFE is to assist people to navigate the health and social care system; however, the intent behind the co-ordinator role is similar to that of the local co-ordination role in the Australian insurance system, and as it is already being promoted in Scotland, it may be worthy of further consideration in relation to social security and joining up services for disabled people.

Recommendation 5 : For Social Security Scotland to strengthen its Local Delivery service partnerships to ensure that appropriate links are made to signpost or refer clients seeking assistance in connection with Adult Disability Payment to local services (with the client’s consent) so they can ensure they get access to the help and support they may need. This should include identifying areas of best practice in partnership working to continue to enhance the service for Adult Disability Payment clients.

Accessing pre-application advice and support

Accessing support to make an application appears to be a vital and effective way of improving benefit take-up among seldom-heard groups. However, a lack of knowledge of where to go for support can present a barrier to applying.^[85]

I heard from stakeholders that many disabled people recognise brands such as Citizens Advice Bureaux because they are well-established and perceived to be independent and they choose to seek advice from them rather than the Local Delivery service. In addition, people who are already part of a community where advice and support are provided often feel that their needs are better met there. It is important to note, however, that the remit of the Local Delivery service is to provide pre-application support, rather than advice to clients.

“When a benefit check with one of our Social Welfare Specialists identifies an individual is eligible to claim ADP, we have a 100% take up record of them going on to make a claim - with the guidance and support of one of our specialists. After completing and submitting the ADP application form, nearly every person has reported they would not have been able to cope with their claim without our expert help and support. In our experience, contact with our service and subsequent discussion about possible entitlement then provides the person with confidence and assurance that a claim is justified and appropriate. Without this, the claim might not be made at all. This is because we have expert awareness of how their condition affects people and how this dovetails with ADP entitlement.” – Multiple System Atrophy Trust response to the Independent Review of Adult Disability Payment Call for Evidence^[86]

Responses to the consultation highlighted that there is a notable lack of awareness about the support available pre-application, such as the Independent Advocacy Service provided by VoiceAbility, and what is available via Local Delivery teams. In a recent Social Security Scotland Client Panels survey, the majority of respondents (57%) had not heard of the Local Delivery service.^[87] Where people are aware, there is a level of suspicion about independence and a lack of clarity over what precisely the services offer. Some other stakeholders have expressed concerns about the potential for actual or perceived conflict of interest inherent in benefit application support being delivered by the same agency that will determine eligibility. This concern is especially acute in the context of re-determination requests.

Consultation respondents who used the Local Delivery Service reported a positive experience with their adviser and appreciated that the meeting could be held in a preferred location. Similarly, those who had used the Independent Advocacy Service felt that they had been fairly treated. A few consultation respondents mentioned long wait times and trouble accessing these services as barriers to uptake.

“The local delivery team were described as helpful in mitigating the distress caused by completing the ADP application, particularly where the applicant has a history of trauma. For example, link worker staff stated that people that use our services had told them that the volume and detail of information required in an application for ADP can be triggering, especially those who are writing down the symptoms they experience as a result of trauma. One person we support felt unable to have the physical copy of their evidence and application form within their house as seeing their experience in written form was triggering for them. This has been mitigated with support from the local delivery service, as the service can visit applicants and take evidence for the application orally.” – SAMH response to the Independent Review of Adult Disability Payment Call for Evidence^[88]

The parts of Social Security Scotland’s pre-application services that are working well include some respondents emphasising that Social Security Scotland staff were helpful when they called with questions. The Minority Ethnic Carers of People Project (MECOPP) and Citizens Advice Scotland emphasised that home visits are a very useful aspect of the services provided, and Feniks and Age Scotland noted the success of the language support and interpretation services offered by VoiceAbility and Social Security Scotland respectively.

Some clients reported that when they are being supported by a third party, they can feel like a burden on the person supporting them due to the long wait times for the third party to get through to speak to someone at Social Security Scotland about their case. One Parent Families Scotland and SAMH have both heard from key stakeholders that timely access to the Local Delivery service could be difficult, although they noted that experiences varied across the country.

Respondents also gave suggestions on what else could improve the service including:

• improved communication
• reduced waiting times on the phone lines
• more information prior to the appointment with the adviser
• more clarity over next steps after the appointment
• more choice around the location, timing and length of appointments.

While generally happy with their experience with the Local Delivery service, a few respondents to the consultation highlighted that because their Adult Disability Payment application was very long, they required multiple appointments with the service. Some people felt that improved staff training is required, particularly to address a lack of awareness of certain conditions and the impacts they have on daily living.^[89]

I have received generally positive feedback about the support people have received from the Local Delivery team, to help them complete the application form. One person told me that the support they received was invaluable as:

“they teased out aspects of how my condition impacts on my ability to do things that I would have never considered” – Individual, MS Society Scotland response to the Independent Review of Adult Disability Payment Call for Evidence^[90]

Another person explained how the support they were given helped:

“it was like they were translating what I said into language that would make it easier to get an award, I am not sure I would have been able to explain my condition as clearly without this support.” Individual, MS Society Scotland response to the Independent Review of Adult Disability Payment Call for Evidence^[91]

However, when compared to a more holistic welfare advice service, although the service is appreciated by those who use it, Local Delivery is still perceived as limited. Some people suggested that if they can get good advice, support and help to fill in the form all in one place why would they use a limited service.

In the three years from its launch in January 2022 until the end of 2024, the Independent Advocacy Service provided by VoiceAbility has received 11,385 referrals, leading to over 9,878 advocacy cases and supported 8,704 people in Scotland, of whom 7,884 were people going through the Adult Disability Payment process.^[92] The results of the VoiceAbility client survey for the period July 2023-April 2024 show that the vast majority of people who used the service were satisfied with the support they received with 90% rating their overall experience as ‘very good’.[93]

One response to the call for evidence suggested than an automatic referral ‘opt-out’ provision be built into the system going forward.^[94] The respondent believed that there are several advantages to this model in relation to streamlining service delivery, better client experience, increasing uptake, and building up robust data to support service modelling. The client keeps the right to opt out of the advocacy service at any time, but it means that the client isn’t required to go through their own self-referral process, nor do they have to rely on others being aware of the service to refer them.

I spent a day shadowing an Independent Advocacy Service advocate in Aberdeen. It is evident from the conversations I had with some local community members, and the team at the Tillydrone Community Flat, how valued the service is. The advocate I met can provide support to people whose first language is not English, and this part of the service was particularly welcomed. The team at the community flat really welcomed an advocate being based a few days a week on their premises. The fact that people can just drop in for a chat and that there is no rigid appointment system as there is with the Local Delivery service, was also seen as a positive.

“People do not need an advocate who cannot advise. This needs to be looked at. Funding needs to be diverted to advice services for disabled people. The term advocacy is not being used in the correct way and it [is] not the correct service to access benefits. People need Welfare Rights Advice to access their rights and entitlements.” – FAIR Ltd response to the Independent Review of Adult Disability Payment Call for Evidence^[95]

However, I do note that the Service Standards for the Independent Advocacy Service^[96] (as required under the Social Security (Scotland) Act 2018)[97] state that advocacy and advice must be provided separately. The Independent Advocacy Service therefore cannot provide advice. The Scottish Government’s position is that it developed the current Service Standards with input from organisations delivering advocacy.

I enquired about the training and development available to advocates and although there is obviously very thorough and comprehensive training (including accreditation) in relation to being an advocate, I was surprised that in this case, there wasn’t more training available in relation to Social Security Scotland processes, and training relating to specific benefits such as Adult Disability Payment. It may be that because of the importance of the independence of the advocacy service it is felt that this would not be appropriate. Social Security Scotland has confirmed that it does provide introductory e-learning materials about the benefits it delivers, including Adult Disability Payment. It has also fed into the development of the original learning and development materials used by the Independent Advocacy Service.

The most recent Social Security Scotland Client Survey showed that almost half of respondents (46%) received help to complete their Adult Disability Payment application with one-in-four (26%) of those who received help with their application getting help from a friend or family member and around one-in-five (18%) getting help from Social Security Scotland. 45% received help from welfare benefits advisers, housing support workers, money advice organisations and other welfare rights services.^[98]

I heard anecdotally from some of the welfare advice organisations who have been involved in the Review that the success rate is higher when a person has received independent advice and support to fill in the application form, although I have no evidence to support this theory. Increasingly, support to apply is lacking and there is evidence that reduction, fragmentation and withdrawal of services providing support with benefit applications are creating significant barriers to improve take-up especially among seldom-head communities.^[99]

A report by Get Heard Scotland Citizens Panel published in 2024^[100] found that many panel members identified that having support and encouragement was a turning point in feeling able to apply for their entitlements, for example from a healthcare professional or welfare rights advisor. This was important for people to demystify the system, understand their rights and entitlements, and how to go about applying for them, often at times of trauma and crisis.

“If we are saying access to benefits is a human right - we need to know what those rights are. If we don't know, we can’t use them and hold government to account.” – Participant, quoted in the Get Heard report^[101]

I met many welfare benefits advisers and support workers from third sector organisations who collectively support thousands of people to apply for Adult Disability Payment in any given year. In most cases there is no statutory funding provided to organisations to provide this service with most charities relying on fundraising income. The Scottish Government’s approach to the funding of advice services is stated as ‘intending to maximise household incomes, tackle problem debt and reduce poverty’.^[102]

Most government funding is allocated via grants to third sector organisations which have a national reach. However, they also invest funding in initiatives that target priority groups or that explore innovative approaches which may support the advice sector as a whole and those that work within it. The Scottish Government invested over £4.6 million to specifically support the delivery of welfare advice and income maximisation services in 2024-25.^[103]

For most independent welfare advice services, the funding is a mixture of debt advice levy and Scottish Government resource funding. The debt levy represents a significant proportion of the overall advice services budget with the remaining proportion coming mainly from Scottish Government resource budgets. As the debt advice levy is restricted in its’ use, i.e., for debt advice services only, the Scottish Government supplements the levy with resource funding, in order to fund wider, holistic income maximisation and welfare advice alongside debt advice provision.

This is in addition to the support made available to fund Local Delivery and the Independent Advocacy Service and the continuation in some areas of Welfare Advice and Health Partnerships. The Welfare Advice and Health Partnerships pilot ran in urban areas from 2021 to March 2024 following provision of additional continuity funding, and in remote/rural areas between 2022 and 2025.^[104]

It is clear that advice and support has proven invaluable to those that have had access to it, however, more needs to be done to promote benefits advice, the Independent Advocacy Service and Local Delivery service so that more people can access the right level of support in a timely manner. If help is not accessible to everyone then there is a chance that a two-tier application process may develop, with the risk that people who apply without support are not receiving the level of award they would qualify for if they were given more advice and guidance.

Observation 1 : The user experience of Adult Disability Payment is linked directly to the provision of independent advice and support to clients with the application, re-determination and appeals process and is essential to the realisation of the human rights of the client. There are many advice services across Scotland that clients recognise and trust, as they will be familiar with these services. Ensuring that they are appropriately resourced to support disabled people with Adult Disability Payment is essential to the realisation of a client’s human rights. The Scottish Government should consider how it is effectively placed to ensure that these services receive appropriate support in the delivery of vital services.

Recommendation 6 : Social Security Scotland should ensure that it actively promotes and gives due prominence to independent advice services to both potential and current clients, including in materials that clients receive from Social Security Scotland.

Recommendation 7 : Social Security Scotland to increase and improve the promotion of the Local Delivery service and the Independent Advocacy Service.

Recommendation 8 : Introduce a dedicated route to speak to Social Security Scotland about Local Delivery and to book appointments.

Recommendation 9 : Improve Local Delivery staff training to address a lack of awareness of certain conditions and the impacts they have on daily living.