Independent Review of Adult Disability Payment: final report

Executive Summary

My findings suggest that improving access to Adult Disability Payment could enhance the lives of all those who need support and who currently either face barriers to getting it or are not eligible under the current system. This builds on existing evidence that underscores the need for a review of the eligibility process and decision-making framework.^[10]

Disabled people have told me that the application process, although much kinder in nature, is still at times inaccessible, complex and burdensome, causing some clients significant stress and anxiety. Building on great foundations and continuing to focus on a good client experience, simplifying and improving systems and processes and refreshing the eligibility criteria could make a substantial positive difference on the lives of all those who need this additional support.

The understandable argument to control public spending and to ensure fairness of allocation suggests that governments should look to limit eligibility and reduce or certainly not increase the numbers of people receiving disability payments. The Scottish Fiscal Commission forecasts in December 2024 noted that applications in the UK are expected to continue to rise in the near future^[11]. The May 2025 forecasts noted changes that are anticipated to impact on benefits expenditure spending in England and Wales:

“The UK Government announced several policy measures, in March 2025, to reform elements of the UK welfare system with the aim of reducing spending and helping disabled people and people with long-term health conditions into employment. These measures include changes that are expected to reduce spending on Personal Independence Payment (PIP) and Carer’s Allowance in England and Wales.” – Scotland’s Economic and Fiscal Forecasts, May 2025^[12]

However, my recommendations suggest that the Scottish Government should not restrict eligibility or introduce further barriers to application. Anything in practice, that opposes the human rights approach currently adopted by the Scottish Government and Social Security Scotland could potentially harm the quality of life of many disabled people.

If viewed as an investment in the people of Scotland there is evidence of the economic value of the wellbeing impacts of disability benefits and these significantly outweigh the financial costs associated with administering them.^[13] This means not only should we continue to encourage people to apply for Adult Disability Payment, but we also need to make the application process as accessible and anxiety-reducing as possible.

In determining my recommendations, I used the questions from the Charter Measurement Framework^[14] to determine if Social Security Scotland, in the context of delivering Adult Disability Payment, is realising its ambitions or if there is still work to be done. As a result, this report and the resulting recommendations are set out under the following four headings:

A People’s Service – recommendations include continuing to place the client voice at the heart of continuous improvement and enhancing the client experience to ensure it is truly person-centred; to further develop strategies to effectively engage with seldom-heard voices and individuals who may be eligible but do not apply due to stigma and to address the societal and sometimes cultural stigma associated with disability benefits to ensure broader and fairer access; ensuring the funding available to third sector advocacy and welfare advice organisations to support disabled people is sustainable and actively promote and share information on the range and location of advice, advocacy and support services available to potential clients; to ensure that taking a trauma informed-approach to practice is embedded in all aspects of Social Security Scotland’s work and ensure people are always treated with dignity, fairness and respect. Everyone who is eligible for Adult Disability Payment should have an adequate level and type of support, offered in a timely manner, to maximise the chances of the right decision being made first time.

Processes That Work – recommendations include improved systems that allow people to track and follow the progress of their application; reduced phone waiting times and faster, more transparent decision-making; reviewing 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; consideration of the feasibility of introducing ‘implicit consent’ and introducing a process that meets the needs of third-party representatives and their clients; for Social Security Scotland to continually assess how it can balance the need for fairness and equity with the discretion that is inherent in the determination process and ensure rigorous application of the reliability criteria; for consideration to be given to automatic entitlement to Adult Disability Payment when satisfying certain conditions.

A Learning System – recommendations include further training and guidance for case managers on certain conditions and the impact they can have on a person’s daily life; specific guidance on fluctuating conditions, and; the reinstatement of an ‘expert by experience’ group to guide the next stage of the evolution of Adult Disability Payment. It is also recommended that Social Security Scotland should consider updating the suite of guidance available to clients and review its inclusive communication practices and set out whether it intends to highlight and make more prominent the option to request written translations of letters.

A Better Future – recommendations include suggested changes to the points-based scoring system to ensure fairness; undertaking a thorough review of the decision-making criteria; providing further training and guidance for case managers to aid good decision-making; replacing the 50% rule with improved application of the reliability criteria; removing reference to a fixed distance in the mobility component, and; improving the questions asked of applicants within the application process, to account for variability, triggers and actions taken to manage conditions.