Independent Review of Adult Disability Payment: final report

A Learning System

It was evident throughout the course of my review 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.

The Chief Executive Officer of Social Security Scotland, David Wallace said in in the Annual Report 2023-24:

“As the number of people we serve grows, we continue to listen, learn, and act on the feedback we receive from our clients and stakeholders. Their feedback helps us ensure we are delivering the best possible service to the people of Scotland while also delivering value for money” – Social Security Scotland Annual Report 2023-24^[205]

In this report I have already recorded examples of where Social Security Scotland uses feedback to improve performance and how they demonstrate that learning from experience is embedded into practice particularly in the case management space. In addition, I have experienced the Social Security Scotland quality assurance process and seen evidence of the ‘feedback loop’ operating between Social Security Scotland and policy colleagues at the Scottish Government.

Some of my conversations with Social Security Scotland staff provided clear instances of times when staff feedback led to an improvement. A common theme was improvements to internal processes which were put in place to manage workloads. There were also examples about improvements to communications within and between teams.

Although several stakeholders expressed not being listened to or engaged with effectively, several also gave examples of where they had provided feedback that led to improvements. One gave an example related to issues of accessibility for clients who use British Sign Language, and another told me that they had seen improvements to the application form as a result of their input.

Communication

Although the lack of proactive communication or progress updates on applications after submission were themes within the consultation, in the most recent Social Security Scotland Client Survey^[206] most respondents agreed with the statement ‘I got the support (information or advice) I needed’ (69%). The survey covers all benefit recipients, so it is worth noting that respondents with experience of applying for Adult Disability Payment were less likely to agree with each of the statements regarding communication choices and support received.[207] Other areas highlighted in the online consultation included the long waiting times for a decision and the long waiting times for someone at Social Security Scotland to answer the telephone helpline, as well as staff not being able to provide adequate progress updates on a person’s application over the phone.

As mentioned earlier in the report, within the Social Security Scotland Business Plan 2024-25, it states:

“we know that our clients want to hear updates from us about their applications. Improving how we communicate with people applying for Scottish benefits will improve their experience while making us more efficient.”^[208]

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 Social Security Scotland to meet legal and organisational commitments regarding inclusive communication.

Members of the group provided expert opinion and insight across a number of areas, including the use of visual imagery in the Adult Disability Payment application form; the approach to consultations and decision-making; and the design of Social Security Scotland buildings.

The Group members worked collaboratively with Social Security Scotland to progress various recommendations in the inclusive communication action plan. The plan has now been incorporated into a wider Inclusive Communication and Equality Strategy as ongoing work is mainstreamed into day-to-day activity.

The Social Security Scotland Client Survey 2023-24[209] highlighted lower satisfaction rates overall among people with specific communication needs.^[i] The survey highlighted that:

• the overall experience rating for people with communication needs (78%) was lower than that for those without (81%)
• respondents with communication needs were less likely than those without to agree that they had a choice of how to communicate with Social Security Scotland (74% and 80% respectively)
• 9% of those with communication needs said they had experienced discrimination, compared with 5% of those with no communication needs.

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. The determination and re-determination letters currently have the name of a manager on them and in discussion with Social Security Scotland I have heard that there are plans to change that for 'safety reasons'. It is evident why having a named point of contact may be operationally challenging; however, the point of having a more personalised and accessible route to two-way communication throughout the application and re-determination process is worthy of consideration. Interestingly when the name of a person along with their signature was removed in a testing environment most people didn’t notice the change. A small number who did notice didn’t like the idea that the name had been removed with their main concern being who to get into contact with if they had questions about their application.

Accessibility and language considerations came up frequently in the consultation, as did noting a person’s preferred method of communication and this not always being adhered to. The evidence reveals the vital role of ensuring that the person’s appropriate communication method is recorded at the outset of an application and acted upon consistently through the application journey.^[210] Failure to do so can undermine people’s agency and their ability to provide all relevant information in support of an application. Failure to use the most suitable communication tool can also worsen the impact of delays.

SCoSS undertook some research on the experiences of people with communication needs and their interactions with Social Security Scotland.^[211] This research was not specific to Adult Disability Payment clients, but the findings are relevant to this Review. These include:

• enhancing understanding of the process among clients and representatives, including continued review of communication by Social Security Scotland to ensure information is as clear, accessible and understandable as possible
• more regular communication, which would be expected to have a positive impact on people especially people with mental health problems or who are neurodiverse, who are frequently also dealing with delays accessing other services while often juggling work or caring responsibilities.

When asked about the reasons for understanding or not understanding the award decision the most prevalent theme in response to this question was confusion about why the client received the points they were awarded, often reflecting disagreement with the decision. Some respondents on the other hand provided positive comments about the clarity of communication around their award.

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. I actually cried reading my PIP letter and felt sick to my stomach. My ADP letter, although hard to read those things about myself, they said nothing derogatory or discriminatory about me.” – Individual, response to the Independent Review of Adult Disability Payment Consultation^[212]

Stakeholders provided a mixed response to the issue of decision letters. Some felt determination letters were too long and information about appeals, and redetermination should be given more prominence on the front page so applicants can quickly access the decision and its implications. Others felt that the current decision letters make it much easier to form the basis of a re-determination request or appeal.

I was told by stakeholders that ‘cut and paste’ is sometimes being used in determination letters with welfare advisers in particular noting word for word similarities in different client determination and re-determination letters. They also noted that determination letters are much shorter and less detailed than they used to be which makes it difficult for the client to understand the reasons why a certain decision has been made.

The introduction of written translations of Adult Disability Payment determination letters was welcomed but it was felt that more languages should be added to ensure the needs of minority communities were better met.

Whilst SRTI is outside of the scope of the review, Social Security Scotland has explained that if a client does not want to know that they are terminally ill, an indicator will be placed on a case reference note highlighting that a person is not aware of their prognosis and communications will reflect this. Individuals with terminal illnesses told me that they do not see themselves reflected in communications, which impacts their engagement with the Adult Disability Payment system. Clearer, more inclusive language is needed to ensure these individuals feel adequately represented.

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.”

One member of the Advisory Group suggested that if Social Security Scotland data about the relatively low uptake of SRTI provision (which makes up 2% of the overall (not just Adult Disability Payment) case load) was highlighted in promotional materials and on the Social Security Scotland website it might act as an incentive to improve communication and messaging to people with a terminal illness and to professionals involved in their care.

Some other communication issues that were raised during the course of 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 for Adult Disability Payment process
• 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 appropriate communication methods are being used at all points in the journey
• unsolicited telephone calls in an attempt to fill gaps in information that continue to cause distress and confusion.

“Some participants said they had been in contact with multiple advisers and had to either repeat the same information they had already given, or were given information which appeared to them to be inconsistent with what another adviser had said” - People with communication needs and the Scottish social security system: fulfilling the expectations of ‘Our Charter’ (2025), Scottish Commission on Social Security^[213]

There are several ways in which communication processes could be improved for people with energy impairment. Ideally there is a need for methods that do not require engagement in ‘real-time’ to accommodate fluctuating energy levels. For example, email correspondence means people can provide information when energy levels permit, in short bursts or on good days. Alternatively, if real-time communication is key, it can require less energy to process information on video calls than phone calls.^[214]

In meetings with LGBT+ disabled people and stakeholder organisations, accessible communication and appropriate terminology were frequently raised. There was a request for all staff involved in the process (local delivery, advocacy, call handlers, case managers) to adopt LGBT+ friendly language, for preferred pronouns to be accepted and wording that respects a person’s expression of gender identity to be adopted. They asked that individual needs are provided for so that equal access to services is achieved with no discrimination and that actions publicly demonstrate a commitment to open and inclusive approaches, including developing administration systems that can easily change 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.

Social Security Scotland has a communication needs indicator that is included on a client record and clients are invited to share any communications needs or preferences during the application process. SCoSS found in recent inclusive communications research conducted, that there is often some reluctance to ask for help among participants, often as a result of a desire to maintain independence and autonomy.^[215] Participants in this research indicated that proactively being offered support might be more readily accepted.

Since Adult Disability Payment launched, Social Security Scotland has offered emails for some non-statutory client correspondence. This included contact to notify clients that it had received their application. In 2024, in response to continued client requests for more digital communication options, Social Security Scotland launched a pilot to assess feasibility and benefits of email-based communication. Currently, it only sends non-statutory correspondence about the annual uprating (the uplift in benefits) via email, with a process to monitor failures in receipt, with a follow-up letter, if needed. It is obviously important that Social Security Scotland complies with data protection laws and considers the needs of a variety of audiences as part of this work, including people whose first language is not English. I understand that whilst a transition to fully digital client communications is not currently possible, work remains 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.

Learning from other pieces of work

Audit Scotland

During the Review, I met with the team from Audit Scotland who are conducting an audit into Adult Disability Payment. Although the independent review and Audit Scotland’s work are different in scope and approach, there are obvious overlaps, and we agreed to keep each other updated as our respective pieces of work progress.

The Audit Scotland audit will look at how well Adult Disability Payment is being managed and assessed, how well the financial and non-financial consequences of this approach are being managed, and if Adult Disability Payment is contributing towards wider efforts to improve outcomes for people with disabilities.

The Audit Scotland audit will provide assurance on how well Adult Disability Payment has been implemented and the added value of the approach taken in Scotland. It will deliver findings and recommendations on the delivery of social security and the future affordability of benefits payments. The overall aim is to assess how much value the Scottish Government is adding through its approach. The audit questions to support this aim are:

• how well are the Scottish Government and Social Security Scotland managing and assessing Adult Disability Payment?
• how well are the Scottish Government and Social Security Scotland managing the financial and non-financial consequences of its approach?
• to what extent is the Scottish Government considering how Adult Disability Payment is contributing towards overall efforts to improve outcomes for people with disabilities?

The findings and recommendations from the audit will provide lessons on the delivery of social security in Scotland and the future affordability of benefits payments. It will also assess the impact Adult Disability Payment has had on overall efforts to improve outcomes for people with disabilities. The Audit Scotland work will be carried out throughout 2025 with a plan to publish the audit report in Autumn 2025.

Minimum Income Guarantee

The Scottish Government funded an independent Steering Group to research the feasibility of piloting a Citizens’ Basic Income in Scotland. In June 2020, the Steering Group published a report concluding that piloting would be desirable, but the Scottish Parliament does not have the necessary range of social security and tax powers to do so. Any pilot scheme would require further devolution or close cooperation from the UK Government, which was not forthcoming.

“The Scottish Government has committed to start work in this parliamentary term to deliver a Minimum Income Guarantee (MIG) in Scotland, incorporating the idea of Universal Basic Services as part of this work. A MIG can be described as a guarantee that everyone will receive a minimum level of income, and can be delivered through a combination of employment, social security and other policies. A Scottish MIG may contribute to reducing poverty over the next parliament so that everyone in Scotland has enough support to live a dignified life.” – Letter from former Minister for Social Security and Local Government to Social Justice and Social Security Committee^[216]

A MIG is an assurance that no one will fall below a set income level. This could be delivered through a combination of fair and accessible paid work, high-quality services that reduce household costs and adequate social security.

During the Review I met with Russell Gunson, Chair of the MIG Expert Group. There are obvious connections between the MIG work and the Independent Review as they both directly or indirectly relate to poverty and wider Scottish Government policy on accessing work, reducing household bills and providing adequate social security.

A Steering Group was appointed in 2021 and includes a Strategy Group of cross-party MSPs and an independent Expert Group with membership drawn from across the third sector and academia.

The 2023 Programme for Government included a commitment to continue to work with the MIG Expert Group, to consider feasible steps towards delivering a MIG in Scotland.

The MIG Expert Group considered the potential impacts and delivery options for both households and the wider economy and society. Its recommendations considered costs, legislative powers and delivery mechanisms – to ensure that they are deliverable. The Expert Group published an interim report in March 2023^[217] which highlights the need for a robust safety net and long-term action to tackle poverty, financial insecurity and broader inequalities across Scotland. The report sets out early considerations for the Scottish Government which could prepare the ground for a MIG. The roadmap includes calls to reform social security policies, address inequalities, improve employment conditions and opportunities, pilot MIG, improve services and reduce household costs. The Expert Group appointed an Experts by Experience Panel to ensure that a MIG is developed with the voices and experiences of financial insecurity at its core. The Panel were tasked with deliberating key elements of a MIG from the level at which it is set, the role of work, what services should be included, and much more. The final report from the Experts by Experience panel was published in July 2024.[218]

While there was no universal consensus, members reflected throughout on the potential societal and economic benefits of introducing a MIG.

The MIG Expert Group published its final report on 18 June 2025.^[219] The Group said:

“Our vision from 2036 is that we work to progress implementation, balancing the role of work, services, costs and social security to successfully manage our social needs with our economic needs. Through fuller powers and flexibilities or through action from the UK Government we are now able to regulate the costs of essentials more fully, and to shape the world of work. Everyone has access to the essentials of life either for free, or at an affordable cost, with income from fair work and/or social security making this possible.”

To this end they have adopted a Roadmap approach, outlining how Scotland can deliver a full MIG, step by step. They combine long-term vision with near-term steps that mean significant progress can be made straight away, even if full implementation will take time, investment and action.

Research

During the Review, I have engaged with many stakeholders and organisations, several of whom have been happy to share relevant pieces of research with me. I have quoted from said research on a number of occasions throughout this report and I would like to take this opportunity to express my gratitude. All relevant research has been passed on to colleagues working in Scottish Government or Social Security Scotland to enhance their awareness and learning.