Independent Review of Adult Disability Payment: final report

Passporting

Passported benefits are benefits, entitlements or concessions that people receiving a specific rate of the daily living and mobility components of Adult Disability Payment may be entitled to.^[42] Examples of passported benefits in relation to Adult Disability Payment include some benefits administered by the DWP, such as specific additional premiums in Universal Credit and Employment and Support Allowance.

The UK Government has agreed that whilst the eligibility criteria for Adult Disability Payment and PIP remain broadly aligned, people receiving Adult Disability Payment can automatically access the same passported benefits that someone getting PIP would receive from the DWP.

There is already a risk of divergence considering the UK Government’s announcement to introduce changes to the eligibility criteria for PIP in 2026 as part of its Pathways to Work Green Paper.^[43] This includes the requirement that in addition to scoring a minimum of eight points to be eligible for the daily living component, the person must also qualify for a minimum of four points from a single descriptor (although at the time of publication the UK Government has signalled that this will now only apply to new applicants of PIP).

The significance of protecting clients who need to access passported benefits cannot be overstated.

“Several argued that changes should not disrupt or adversely affect clients i.e., clients should retain their existing entitlements regardless of any changes made to ADP, and none should become worse off.”– Consultation on the Mobility Component: Analysis^[44]

My engagements with disabled people and stakeholders during the course of the Review have highlighted the concerns that many people have with regards to accessing passporting benefits, as highlighted in the consultation and call for evidence analysis.^[45] During engagement events, disabled people and third sector organisations spoke of their concerns about the qualifying periods for Adult Disability Payment (which are identical to PIP) which had resulted in delays to receiving passported benefits. Furthermore, participants highlighted the stress and anxiety caused by processing time delays for decisions on an Adult Disability Payment application. This has meant that that they have been unable, in some cases, to access passported benefits.

Equally, people have expressed views that passporting arrangements should not constrain future ambitions for Adult Disability Payment in Scotland.

However, should the Scottish Government consider making any changes to the eligibility criteria because of my Review, passporting remains a crucial issue for the people it affects. There are both fiscal and practical challenges to any potential changes to passported benefits, for example:

• the way that the UK Government might respond to any changes is rightly a matter for it, although it has said if it cannot use Adult Disability Payment to identify people entitled to a passported benefit, it would identify another way;^[46] the practical extent to which it might do so might mean that arrangements could look very different for disabled people
• if changes to the eligibility criteria result in more people qualifying for UK Government passported benefits, resulting in increased costs for the UK Government, the Scottish Government would be required to cover these expenses under the Fiscal Framework agreement.^[47]

Whilst it is outside the scope of this Review to recommend how the UK Government should respond to any potential changes to Adult Disability Payment; I would urge both Governments to engage at an early stage on this matter. This would benefit disabled people by providing certainty and putting them at the heart of any considerations.

In terms of costing the impact of potential changes to the eligibility criteria on passported benefits, this would first require an understanding of the changes in the number of people who would qualify for Adult Disability Payment. That work is a far larger undertaking than is possible within the scope of this review, as it would require a comparison between how many people would qualify under the old rules and then comparing that to the new rules. The Scottish Government may be able to undertake this, for example by:

• reviewing the activities and descriptors
• taking a sample of applicants, and then undertaking qualitative research to explore whether the suggested changes would have caused them to make any changes in what they put in the application
• taking a sample of decision makers to then look at that data along with the new activities and descriptors, to see how they would interpret and score those
• undertaking a comparison of the points awarded in the first instance and the second.