Independent Review of Adult Disability Payment: final report

Annex 2: Impact of Making Changes

It is important to recognise that should the Scottish Government decide to accept the recommendations in my report, there may be costs involved. These can be thought of in two terms:

• Benefit expenditure costs: these are the value of payments made to individual clients, so are likely to continue into future years
• Benefit delivery costs: these are the costs associated with implementing changes to systems, processes and procedures.

Benefit Expenditure

Estimating the change in benefit expenditure as a result of implementing individual or combined recommendations can be challenging. Alongside data requirements and assumptions that are needed to make robust calculations, there may also be behavioural changes from clients, particularly in the way in which they respond to questions, or activities and descriptors. Given the scope for this behavioural change, it may take a period of time for any change in trends to become established enough for costing analysis to be completed.

The specific nature of how recommendations would be implemented or appear in practice as part of Adult Disability Payment processes, would likely depend on further evaluation or design by Social Security Scotland. Data that directly captures, or can be used to estimate, how these changes might influence the number of applications received or the outcome of determinations, would be required to make a comparison to how Adult Disability Payment was delivered before these recommendations were implemented.

Total Adult Disability Payment benefit expenditure broadly depends on the number of people receiving Adult Disability Payment, in combination with the award level each of those people receive. For example, benefit expenditure for Adult Disability Payment may change where recommendations:

• influence a change in the volume of applications received by Social Security Scotland
• influence a change to the authorisation rate for new applications
• influence a change to the outcome of award reviews
• influence a change to the amount of time people receive an award
• lead to more people applying for redeterminations or appeals
• lead to a difference in the outcome of redeterminations or appeals.

Statistics capturing many of the above are published by Social Security Scotland, which can give an indication of how these may influence benefit expenditure.

Adult Disability Payment remains a relatively new benefit and some of the longer-term trends are still becoming established. Given the influence of the different factors above in determining benefit expenditure, new trends may take time to present in the data and for the effect of recommendations to become clear.

The Scottish Fiscal Commission, in their earlier Scotland’s Economic and Fiscal Forecasts series, had anticipated an initial spike in applications for Adult Disability Payment and a longer-term uplift in applications compared to before Adult Disability Payment was launched. While determining the true scale of any behavioural change and differentiating that from other factors driving applications is difficult, this may demonstrate the influence that behavioural change and delivery choices could have.

Using factual information provided by Scottish Government officials, I have considered the information provided by those officials whilst forming an independent view as to having appropriate assurance that the potential costs of any changes to benefit expenditure have been considered, in reaching my recommendations.

Review of Recommendations for Benefit Expenditure Estimates

Of the 58 recommendations outlined in my report, producing estimates of the potential scale of the impact on expenditure, can be more straightforward where these relate to specific cohorts of people and where data is more readily available.

Illustrative estimates of the scale of benefit expenditure, for recommendations where particular cohorts of people or data have been identified, have been outlined below to give an indication of the impact these might have.

Where it has not been possible to source the information to carry out these calculations, a potential approach to carrying these out, if the recommendations are implemented, is outlined below. Further commentary is provided where recommendations may require more extensive investigation, citing the challenges associated with estimating these at this time.

For recommendations that are more straightforward to estimate, forecasts of the average award rates for Adult Disability Payment alongside the value of daily living and mobility component awards for 2025/26, can be used as a starting point for calculations. Using illustrative scenarios of the number of people that could be brought into eligibility by the recommendations, an approximation can be derived based on the number of people and these different award rates.

In the latest Scottish Fiscal Commission forecasts (May 2025), the average award for Adult Disability Payment in 2025/26 is estimated to be £130.19 per week. The value of an enhanced daily living and enhanced mobility award in 2025/26 is £187.45 per week.

As an example, to give a sense of the scale and a resultant cost estimate, for 1,000 people to receive the average award level for 2025/26, for 52 weeks, it would cost around £6.8 million. For 1000 people to receive the enhanced daily living and mobility award level for 52 weeks, it would cost around £9.7 million.

These estimates can be applied to the scenarios outlined for the recommendations below, to give an indication of the potential scale of additional expenditure that might result.

Recommendation 30: To consider introducing automatic awarding of short-term assistance with an opt-out clause to acknowledge a client’s right to choose.

According to the most recent Social Security Scotland statistics for Adult Disability Payment, 2,245 cases of Short-term Assistance have been paid by Social Security Scotland. This compares to around 3,630 planned award reviews where the outcome of the award was a reduction or stopping of the award.

If it is assumed that only planned award reviews are considered, rather than people reporting an improvement in their condition through a change of circumstances, then out of the 3,630 planned review outcomes that resulted in a decrease or stopping of the award, 2,245 would have requested Short-term Assistance.

In a scenario where the remaining 1,385 were reduced from enhanced to standard awards, a reduction of £84.35 at 2025/26 levels, based on an 8-week redetermination processing time it would have cost Social Security Scotland around £900,000 to pay them Short-term Assistance over this time if they requested a redetermination and Short-term Assistance payments.

The scenarios are outlined below –

• Paying the 1,385 cases Short-term Assistance based on a reduction from enhanced daily living and mobility to standard award levels (a reduction of £84.35) for 8 weeks, would have cost around £900,000.
• If based on Social Security Scotland’s statistics 19% of redeterminations are assumed to go on to appeal, then paying this portion of the 1,385 cases would have cost around £90,000 for every further month that passed.
• If the 1,385 cases were paid Short-term Assistance based on a reduction from the average award level for 2025/26 (£130.19) to no award, this would cost around £1.4 million if paid for 8 weeks.
• If 19% of these went on to appeal, then paying this portion of the 1,385 cases in this scenario would have cost around £140,000 for every month that passed.

It is important to note that while these costs are based on published statistics, the number of award reviews and the outcome of these may be different in future. It is also worth noting that the recommendation in relation to Short-term Assistance would not necessarily result in more people being eligible for Short-term Assistance but rather all, or the majority, of those currently eligible to apply for Short-term Assistance, do so.

Recommendation 32: To re-visit the eligibility rules in respect of cessation of Adult Disability Payment if 28 or more days are spent in hospital.

To estimate the cost of this recommendation, a starting point could be to see if the number of people affected by this rule historically can be identified. Alongside this, if it were possible to identify how long these awards were stopped for on average and what the average award level was, certain assumptions and simplifications could be made to help produce an estimate of the scale of the impact.

As an illustration below:

• Using the number of people who have been affected by the rule, in combination with the award amount and duration where they did not receive an award, the total potential cost if they had received payment could be estimated as a starting point.
• Depending on the number of people affected and the award amount, averages or assumptions about the cohorts of people affected may be needed to simplify the calculations.
• While these provide an illustrative example, any estimates would be dependent on the data available and the caveat that these numbers may change based on future caseload or demand for Adult Disability Payment.

Recommendation 33: For consideration to be given to granting automatic entitlement to Adult Disability Payment when satisfying certain conditions or being in receipt of other forms of assistance without having to satisfy the qualifying period.

It is likely that many of the people below who relate to this recommendation are already aware of, or receive Adult Disability Payment, but the calculations below can demonstrate the potential impact. These have been identified based on the Independent Living Fund as well as Blue Badges, as outlined in the main report. As many people may already receive Adult Disability Payment, a scenario where an assumed 10% of each cohort do not already receive Adult Disability Payment, is illustrated below.

This approach has been taken as it has not been possible to identify the overlap between the different support outlined above and receipt of Adult Disability Payment. As a result it is important to note that the true figures could differ, but these calculations can give an indication of the scale:

• The Scottish Government outlined that around 2,000 people were receiving support through the Independent Living Fund in March 2024. A further 1000 people are due to be supported through 2024/25. If it is assumed that 10% of these people don’t already receive Adult Disability Payment, then supporting an estimated 300 people with an enhanced daily living and enhanced mobility award for 52 weeks, at 2025/26 award levels, would lead to an expenditure impact of around £2.9 million.
• Blue Badges are provided on an automated or discretionary basis. If it is assumed that those who receive an automated Blue Badge already receive Adult Disability Payment and calculations involve the discretionary cohort, this amounted to around 159,000 people in March 2024. If in this scenario, 10% of the cohort did not receive Adult Disability Payment already, then this group receiving the average award level for 2025/26 for 52 weeks would cost an estimated £108 million.

Expenditure for the recommendations noted below may be more feasible to produce should further investigation establish a source for the data required to do so. It has not been possible to source the data between these recommendations being confirmed and finalisation of the report, however a possible approach to deriving benefit expenditure estimates has been described to outline how it could proceed if the information were available.

Recommendation 45: Consider the introduction of a substantial risk provision for people who fail to score points to qualify for an award of the daily living or mobility component of Adult Disability Payment if not making an award would pose a substantial risk to the physical or mental health of the person.

To produce an estimate for this recommendation, a starting point could be to explore whether information on the number of people who may have fallen into this category when applying for Adult Disability Payment could be identified.

If it could be determined how many of the cohort identified above were successful at application or not, then for those who were not successful but would have potentially qualified under a substantial risk provision, the cost of paying a given award level could be estimated.

For instance:

• Based on current and forecast award levels, what would it have cost to pay the cohort who were not successful in addition to the existing caseload.
• This could provide an illustrative estimate but it would be important to recognise any simplifying assumptions, the impact of behavioural changes, or changes in the number of applications in future.

Recommendation 54: For clients who have an appointed financial guardian to receive automatic entitlement to the maximum number of points in the ‘making budgeting decisions’ activity.

Estimates for this recommendation would likely begin with exploring whether information is available on the number of people who had an appointed financial guardian when making an application for Adult Disability Payment.

It would also likely be necessary to explore whether this could be linked to the number of points that clients scored on the making budgeting decisions activity, if not the maximum number already. While it may be challenging to source this information, as with other recommendations, assumptions or simplifications could possibly be made, such as grouping clients by points scored.

If the number of people who had a financial guardian and the number of points scored on this activity could be identified, this could be compared to a scenario where these clients received the maximum number of points in this activity.

If more people are entitled to an enhanced daily living award as a result, then this would increase benefit expenditure compared to the current proportion of enhanced awards on the Adult Disability Payment caseload.

As with other illustrative estimates, it would be important to recognise the assumptions and simplifications made in any calculations, alongside the difficulty in determining any future behavioural changes.

The recommendations not included above are likely to require further investigation, definition, and agreement from Social Security Scotland before expenditure estimates can be produced. Given the different interconnecting factors that are likely to influence application numbers to Adult Disability Payment and the challenges associated with predicting behavioural changes, it may be difficult to assign precise numbers to many of these recommendations before further discussion and understanding can be sought. Some recommendations also relate to more broad themes that may not have any measurable impact on expenditure.

While it hasn’t been possible to attribute expenditure estimates to the remaining recommendations, some further discussion is provided below for each section of the report, on the main challenges and a potential way forward in future.

A People’s Service (Recommendations 1 to 9)

The recommendations in this section relate primarily to ways to address take-up and improve access. There are also recommendations related to better signposting and accessibility of Local Delivery services.

Some of the recommendations relate to broader suggestions to improve take-up through the implementation of strategies to do so, rather than being specific changes to Adult Disability Payment, which would have a more readily quantifiable impact on benefit expenditure. The Scottish Government has published estimates of take-up for certain benefits, however accurately estimating take-up rates for disability benefits remains challenging owing to the absence of reliable data to determine how many people in the population are eligible for the benefit. While any strategy to improve take up would have the potential to increase the Adult Disability Payment caseload and hence expenditure, it would not be possible to quantify the impact of Adult Disability Payment take-up currently.

Similarly with improvements to signposting and training, it is possible that this could influence the number of people coming forward to apply for Adult Disability Payment, however without understanding client behaviour around these improvements it would be difficult to determine any impact on expenditure without some further investigation. For instance, a possible alternative is that the demand could remain similar but the recommendations would make these services more accessible and helpful to those already making an application and their application may have an improved chance of a successful award being made.

As a result, it would likely be necessary for further work to take place before the expenditure implications can be determined fully.

Processes That Work (Recommendations 10 to 34)

Within this section, a number of the recommendations relate to steps to improve the experience and accessibility of Social Security Scotland’s processes to those making an application. They relate to processing times, application tracking, and other steps to improve the journey itself. Steps to implement these recommendations may incur operational costs to Social Security Scotland but it is not clear if any material impact on benefit expenditure would be realised by improving these aspects.

One influence could be that clients find the application process more straightforward, though it is difficult to say whether this would lead to higher demand in the form of more new applications overall.

Where recommendations relate to reliability criteria and decision making by case managers, further investigation would likely be required to explore any measurable change this may bring about to the outcome of people’s applications as a result of these revisions. While the potential impact on application numbers and authorisation rates may be difficult to determine until these changes are investigated and monitored, any estimated change in the overall outcomes for clients could be compared to outcomes prior to the recommendations being introduced.

The above would likely also apply to any change to the communication of, or processes associated with, clients applying for redeterminations or appeals.

As previously outlined, recommendations where a more specific and measurable cohort of clients are affected, whose circumstances are already captured in readily available data, are more likely to have illustrative cost estimates that can be associated with them (including recommendations 30, 33 and 32 covered above). Though subject to the availability of any underlying data, the Scottish Government and Social Security Scotland could look to identify what data exists on these cohorts.

A Learning System (Recommendations 35-39)

Many of the recommendations in this section relate to the way Social Security Scotland communicates with clients to ensure inclusivity and accessibility. Many of these suggestions impact those already making an application. As a result, it would be difficult to comment on how many people either would not have applied without these recommendations, or how it would impact on the approval rate of clients who would have already applied. It is feasible that these changes have little to no impact on overall benefit expenditure as a result.

A Better Future (Recommendations 40-58)

Many of the recommendations made in this section relate to potential changes to the activities and descriptors used by clients and case managers, as well as revised guidance and application of items such as the reliability criteria. Alongside this are recommendations around improved interpretation and definition of how different conditions may affect clients.

In order to anticipate the potential benefit expenditure associated with changes to the activities, descriptors, and decision making, further detail would first likely be required on how any revisions to the activities and descriptors would look in practice. It might be that these and the accompanying guidance require further investigation by Social Security Scotland. In the first instance involving due process to design and consult on the changes before a decision can be reached.

Costing the impact of potential changes to the activities, descriptors, and case manager guidance is therefore a far larger undertaking than what is possible within the scope of this review. The specific methodological approach would need to be explored by the Scottish Government in detail, dependent on what specific changes were identified. The potential research question that would need to be addressed could be:

• How do any potential changes to activities, descriptors, and/or case manager guidance impact:
• Caseload
• Award levels

This question could potentially be addressed through a series of more specific questions, such as:

• How do current clients understand any changes?
• For current clients, would the changes have meant they approached their application differently? If yes, how?
• Is the wording of activities or descriptors prior to the changes a reason why potential clients (e.g., those who are eligible but have not applied to Adult Disability Payment) have not applied?
• Would potential clients be more likely to apply after the changes?
• How many people may apply who would not have applied prior to the changes?
• How do decision makers understand any changes?
• How do any changes affect how decision makers make decisions?
• Are more people eligible for Adult Disability Payment as a result of changes to the activities and descriptors?

If it could be established through further research how a sample of clients and case managers respond to these changes, it may then be possible to compare if the number of people with successful applications under existing criteria, differs to those eligible under the recommendations. It may not be until these are implemented and data starts accumulating, that any new trends can be identified.

The Scottish Government may be able to undertake exploratory work around the feasibility of these questions, however due to the complexity of this work it is not possible to undertake as part of this review.

This is similar with recommendations such as revisiting the mobility criteria. If this is updated to account for specific individual circumstances rather than categorising by distance, costings would require an understanding of how a more qualitative approach would then map to existing mobility award levels.

As with the Processes That Work section, there are recommendations which relate to particular cohorts of people where further investigation of the data could be undertaken. For instance the number of people with a financial guardian or those who have a specific condition, recommendations 47 and 56. If these cohorts can be identified then it is more likely that illustrative cost estimates could be derived.

The Scottish Government may wish to consider a more in-depth analysis of the extent to which changes which result in automatic entitlement for individual components, activities or descriptors would have on administration costs and client satisfaction, for example, does it reduce the time required to process an application, improve client satisfaction with the outcome of decisions, or encourage better take up amongst eligible client groups etc.

Using factual information provided by Scottish Government officials, I have considered the most appropriate way to set out the cost and potential complexities involved in making those changes.

Benefit Delivery Impacts

The Scottish Government established the Social Security Programme to develop the systems that Social Security Scotland needs to deliver its benefits. The Programme sits within the Social Security Directorate in the Scottish Government, but the Programme will close in the current financial year (2025-26). Some of the Programme’s functions will be absorbed into Social Security Scotland, so that future changes to benefit delivery systems and processes will therefore be for Social Security Scotland to take forward.

For example, having spent time with colleagues from the Social Security Programme and Social Security Scotland, I appreciate that what may appear simple in relation to changing questions on an application form can involve a number of unseen changes to the systems, training, guidance and decision-making tools used by Social Security Scotland. That takes time and it also involves a cost, in addition to managing several other devolved benefits.

Social Security Scotland’s case management system (SPM) is a key component of how it delivers its benefits. SPM holds information about which benefits a client is entitled to, including the rates of payment a client is entitled to receive. SPM also interacts with other systems that receive digital applications from clients, produce letters to clients, or give Social Security Scotland management information (MI).

Given that my recommendations, if accepted, would be subject to a detailed technical assessment by the Scottish Government, I have sought to consider whether the recommendations in my report are technically feasible where they involve an element of change to SPM only, as well as illustrative costings for the technical development of those changes.

The following recommendations would involve an element of change to SPM:

• Recommendation 10: Taking into account the findings in this report, review the application form, including its length and reconsider the way the questions are framed to maximise the opportunity for a client to articulate how their disability or condition impacts on their daily life and to reduce the anxiety and stress associated with the task of applying
• Recommendation 13: Develop and deliver a 'Track Your Application' on-line portal making it easier for clients to apply for Adult Disability Payment and to improve communication on the status of a client’s application
• Recommendation 17: For each letter from Social Security Scotland to be stand-alone so there is no need to cross reference with other correspondence and put the date of the correspondence on every page when sending letters to clients
• Recommendation 19: The reliability criteria should be explained clearly both in promotional materials, at the start and throughout the application process with more examples, so that clients understand its importance and have a clear understanding of how it is applied in making decisions
• Recommendation 21: Social Security Scotland should ensure that explicit reference is made to the reliability criteria in all decision correspondence, so that clients and representatives can understand if, and how, the criteria have been applied
• Recommendation 29: For information about appeals, and re-determinations to be given more prominence on the front page of the determination letter
• Recommendation 30: Consider introducing automatic awarding of short-term assistance with an opt-out clause
• Recommendation 43: Improve the questions asked of applicants within the application process to account for variability, triggers and actions taken to manage conditions.

General points and assumptions

The assessment of feasibility is focused on the technical changes required to SPM only. Although I have made recommendations relating to changing the eligibility criteria the following assessment of feasibility has been based on the assumption that there would be no changes to the eligibility criteria for Adult Disability Payment made by the Scottish Government that might otherwise impact on this.

All of these recommendations, if accepted, would be subject to prioritisation within Social Security Scotland, the availability of appropriately skilled staff with knowledge of the existing software and a more detailed assessment of the programme/project management costs. Therefore, I have been told that they might not be capable of being delivered immediately and some of these changes may be capable of delivery sooner than others.

There are variables that also cannot be accounted for, because it depends exactly how the Scottish Government and Social Security Scotland may choose to implement individual recommendations.

Both the cost and the timing of the work exclude:

• changes to paper forms
• project/programme management
• changes to guidance or training
• contingency costs, which may or may not therefore materially affect that assessment of feasibility.

If the Scottish Government accepted each recommendation involving an element of change to SPM, it may be more cost-effective to undertake all of the activity at the same time, rather than commissioning individual projects. The illustrative development costs involved could range from £1.27 to £2.09 million to implement all of the recommendations as a single package of work.

The following illustrative costs have been provided based on the factual information provided by Scottish Government officials:

Table 1 Illustrative SPM development costs for individual recommendations

These costs are purely indicative, and it would require a more comprehensive, technical assessment of all of the requirements involved. Some of the recommendations also involve a higher degree of confidence than others.

Recommendation 13: Develop and deliver a 'Track Your Application' on-line portal making it easier for clients to apply for Adult Disability Payment and to improve communication on the status of a client’s application.

As I have noted in the body of my report, a particular recurring theme has been anxiety amongst disabled people about the state of progress with their application for Adult Disability Payment. The provision of an online portal provides an element of self-service for clients who might otherwise have to call Social Security Scotland or use the web chat functionality to receive updates.

I understand that this recommendation could potentially take longer than the others to implement, because of the technical aspects to it and is not (strictly speaking) an SPM-related recommendation. Social Security Scotland may wish to consider whether it is necessary to develop an entirely new system from the ground up, or whether there is an existing system that could be procured, customised and used to deliver this portal. Social Security Scotland would also need to consider how familiar its teams might be with an existing system that could be brought in to deliver the portal.

Recommendation 30: Consider introducing automatic awarding of short-term assistance with an opt-out clause

Currently, Social Security Scotland administers the handling of applications for Short-term Assistance manually. Social Security Scotland staff enter key contextual details to SPM, including detailed information such as previous decision dates and award values. This helps to ensure that the client receives the right payment, at the right time. Once that process is completed, payments are then issued to clients.

From the factual information provided by Scottish Government officials, developing SPM to work with this recommendation could involve illustrative costs between £120,736 and £189,728. However, there is low confidence both in terms of the potential time and costs involved in implementing this recommendation.

I would therefore encourage the Scottish Government to carefully consider undertaking a more detailed technical and operational assessment of the feasibility of this recommendation, with the aim of reducing the administrative burden on clients, the anxiety of waiting and ensuring clients continue to receive the right payment, at the right time.

Recommendation 43: Improve the questions asked of applicants within the application process to account for variability, triggers and actions taken to manage conditions.

The approach to designing the application process for Adult Disability Payment has involved disabled people and drawn input from stakeholders, to improve the process compared to PIP. It has involved user testing to ensure equity of provision to clients applying for Adult Disability Payment. The significance of that undertaking cannot be underestimated in terms of the time and thought that was given to the format of the current questions on the application form.

I understand that a similar process would be required to inform this recommendation, if it is accepted by the Scottish Government. My understanding is that this recommendation would need a detailed specification of requirements from the Scottish Government: what scenarios should be captured, what questions need to be asked and how they should be asked. It would potentially involve a significant update to SPM as well as other systems and is potentially a significant change.

An illustrative costing of changing SPM would be between £291,060 and £457,380, although this is a low confidence estimate. Whilst I appreciate the element of uncertainty involved, this recommendation (if accepted) would help clients, especially those with fluctuating conditions, to better describe the impact of a disability or health condition, whilst also providing case managers with a better understanding also.

[i] I note that the Client Survey reflects all respondent’s views to the Client Survey and is not disaggregated by the individual benefits Social Security Scotland delivers.