Scottish Government Response to the Independent Review of Adult Disability Payment Final Report

A shared vision for Scotland

A People's Service

Work beginning within three months

11. This theme of the Independent Review’s Report focuses on recommendations to ensure that disabled people remain at the heart of the service Social Security Scotland provides. It recognises the Scottish Government’s commitment to delivering a person‑centred service and highlights the transformative impact this has had on people’s experiences of ADP. The recommendations relate to widening and supporting access to the benefit and continuing to improve how Social Security Scotland communicates with people about disability assistance.

12. The Scottish Government agrees that, as ADP continues to develop and become further embedded, the input of disabled people and Disabled People’s Organisations will remain essential. The Social Security Scotland Client Panels enable people with experience of interacting with the social security system to share their views and insights. Improvements are based on client insight and evidence gathered across representative groups. Social Security Scotland is conducting ongoing research to better understand the experiences of seldom heard audiences. This research has already covered a wide range of groups, including young people aged 16–24, people who speak English as a second language, individuals with varied communication needs, and LGBTQ+ communities. Current research is focused on people experiencing homelessness, survivors of domestic abuse, and individuals living in rural areas. Upcoming research will explore care leavers, veterans, and people with experience of legal detention. Across all groups, intersectionality has been a key theme, highlighting the complex and overlapping identities and needs of clients. The expertise of the Client Panels team will ensure that lived experience remains central to the future of ADP.

13. Building on the progress achieved through the Scottish Government’s Seldom Heard Groups Action Plan, measures will be included in the 2026 Benefit Take Up Strategy to improve access for people for whom traditional approaches may be less effective. By adopting tailored approaches to encourage take‑up among those least likely to apply for ADP, or who face the greatest barriers in doing so, the Scottish Government aims to reduce obstacles to access and enhance the service for all clients.

14. To assess the effectiveness of efforts to maximise take‑up of ADP, including among seldom heard groups, the Scottish Government must be able to estimate the total number of people who could be entitled to the benefit. This is not a straightforward task and, critically, depends on the development of a robust methodology for producing reliable estimates. Work on this is underway, and the Scottish Government will provide an update on progress by the middle of 2026 at the latest.

15. Finally, in relation to access to financial support, the Scottish Government will continue to strengthen the promotion of Local Delivery and Independent Advocacy services through a range of materials and approaches embedded across core activity. This will include the use of leaflets, social media, stakeholder engagement, and community events to ensure that people are aware of and able to access the support available. Beyond signposting, work is on-going to explore supporting the safe and secure sharing of client data with relevant organisations that may be able to provide further support. The Dundee Fairer Futures Pathfinder and the Ask and Act pilot will provide an opportunity to test processes and develop solutions that support clients.

16. The Report highlights the risk that the process of applying for disability assistance may cause additional distress for people who have experienced trauma. To address this, it recommends embedding a framework of trauma‑informed practice within Social Security Scotland’s processes. Social Security Scotland has been working collaboratively with other public sector organisations to embed a national framework for implementing trauma‑informed practice in line with a developed roadmap, and work is ongoing to ensure this approach is consistently embedded across the organisation.

17. The final recommendation under this theme, to be progressed within three months, calls for additional training to address a perceived lack of awareness among Local Delivery staff of specific conditions and their impact on clients. Social Security Scotland regularly reviews the professional knowledge and skills of staff to ensure learning resources remain current and will continue to deliver awareness‑raising through regular learning sessions for Local Delivery staff.

Considering further

18. Several recommendations under this theme relate to the information provided to clients, including in decision letters and other communications about entitlement. Following publication of the Independent Review’s Interim Report, extensive user research and development work was undertaken to ensure that written materials from Social Security Scotland meet the needs of their intended audience. The key finding from this work is that simplicity is paramount. Clients want clear, concise information that is easy to understand, without unnecessary detail. For this reason, the same rigorous process will be applied to these recommendations before any commitment to implementation is made.

Not implementing

19. The only recommendation in this section that the Scottish Government does not intend to take forward is to allow clients to contact the Local Delivery service directly to book appointments. At present, clients make contact through the main Social Security Scotland helpline. This approach ensures that the date of entitlement is accurately recorded and protected, guaranteeing that payments are made in full, from that date. Local Delivery appointments can then be arranged during the same call, providing a streamlined and efficient experience for clients.

Processes That Work

Work beginning in three months

20. This theme contains the most extensive recommendations, covering both the operational delivery of ADP and the client experience, from application through to decision‑making. It reflects Social Security Scotland’s success in delivering a system that treats people with kindness, where clients feel listened to and valued.

21. The Report recognises the work already undertaken to reduce the time clients wait for a decision about their ADP entitlement. Social Security Scotland is committed to consolidating this progress, reducing both decision waiting times and the time people wait to get through by phone.

22. There are six recommendations relating to the decision‑making process and the guidance and training that underpin it. A further three similar proposals appear under the final theme A Better Future and will be considered here also. Of these nine recommendations, four relate specifically to the Decision-Making Guidance. They are intended to ensure staff have a holistic understanding of how health conditions or disability can affect all aspects of a person’s life, and how eligibility criteria relate to these impacts. For example, recognising that someone with chronic fatigue may experience exhaustion hours after an activity, even if they are able to complete it at the time.

23. As part of its commitment to continuous improvement, Social Security Scotland regularly updates guidance and training to reflect policy developments and in response to feedback. The nine recommendations will be implemented through guidance and training so staff can apply them consistently in practice. Work on the four priority recommendations highlighted above will begin within the next three months. In addition, Social Security Scotland will continue to work with policy, legal, and operational colleagues to ensure guidance remains fit for purpose and reflects a learning system.

24. The Report praises Social Security Scotland’s engagement with third sector organisations to enhance knowledge and understanding of particular health conditions. It also highlights the need for a more coherent approach, ensuring greater consistency in how and when such engagement takes place. Social Security Scotland will continue to involve stakeholders in strengthening feedback mechanisms through clear engagement plans.

25. In relation to consultations, the Report describes overwhelmingly positive feedback from clients. While recognising this, it also notes stakeholder feedback that an in‑person conversation may be more accessible for some clients than a phone call. Reflecting these findings, the Report recommends allowing clients to choose to have a consultation, rather than this decision being made by Social Security Scotland.

26. The removal of routine face‑to‑face assessments was a deliberate policy choice by Scottish Ministers, based on the overwhelmingly negative experiences of clients who went through a DWP assessment. In our system, consultations were never intended to be the default mechanism for determining needs. Where required, a telephone consultation is usually arranged to minimise inconvenience and stress. The Report’s findings are noted, and while clients will continue to be offered choice, further work will ensure they are aware that they can request a consultation, in a format that suits them.

27. Recommendations relating to appeals, re‑determinations, and award duration will be addressed by a new ADP determination letter, to be introduced by Spring 2026. Extensive user research has been carried out to make this information clear, personalised, and consistent with the latest information available online and by phone. Further research with clients will assess the effectiveness of these improvements once the new letter has been in use for an appropriate period.

28. Some recommendations reflect specific priorities of stakeholder organisations. One example is a campaign by Young Lives Versus Cancer to continue ADP payments when someone is in hospital. Currently, payments stop after 28 days, as care needs are met within hospital.

29. Young Lives Versus Cancer highlighted the burden this places on people undergoing cancer treatment who require multiple short hospital admissions. Families must repeatedly notify Social Security Scotland of admissions and discharges, adding stress at an already difficult time. The Report therefore recommends revisiting this policy, which the Scottish Government will do.

30. This review will consider the policy rationale, potential costs, client impacts, and operational requirements. As the rule also applies to Child Disability Payment (CDP), Pension Age Disability Payment (PADP), and Scottish Adult Disability Living Allowance, it will be examined in the wider context of disability assistance. This analysis will inform whether the rule should be amended across all benefits.

31. Finally, as part of the Scottish Government’s ongoing commitment to continuous improvement as set out in the social security principles, further enhancements will be made to the disability benefit review process. These enhancements will include improvements to the scheduled review form, which will strengthen the gathering of relevant information at award review, to further facilitate fair and robust decision-making.

Considering further

32. The first two recommendations under this theme, which the Scottish Government is currently unable to commit to implementing, would allow clients to access real-time information about the progress of their application, re-determination, or change of circumstances. Social Security Scotland recognises the value of this personalised service and will continue to explore options for introducing such significant additional functionality.

33. We are currently delivering a focused proof of concept aimed at enhancing the verification process for new corporate appointees within three Local Authorities. While the scope is limited to verification only, this work lays an important foundation for future improvements. The final analysis and recommendations may also inform approaches to maintenance and DWP transfer cases, creating opportunities for broader impact. We are about to begin the evaluation phase and expect to deliver a comprehensive Report in February. At this stage, we’re testing scalability and assessing what aspects can be applied more widely. For now, the focus remains on the Local Authority corporate appointee process. Once the evaluation is complete, senior leaders will review the findings and consider our recommendations to determine the best way forward.

34. The Report recommends that each letter issued by Social Security Scotland should be ‘stand-alone’, with the date on every page, so clients do not need to refer to previous correspondence. It also suggests that determination letters explain how the reliability criteria - whether an activity can be carried out safely, repeatedly, to an acceptable standard, and within a reasonable time - have been considered. While these changes could improve clarity, they may also result in repeated information or significantly longer letters. This will be reviewed in the context of the Social Security Charter and the commitment to inclusive communication.

35. Another recommendation is to provide clients with more detailed information about the need to proactively report a change of circumstance, including what constitutes a change, why it is important to report it, and examples of relevant situations. Clients already receive this information at a level intended to ensure understanding without overload. Social Security Scotland will consider how best to address this recommendation while meeting client needs.

36. The Report also recommends reviewing the ADP application form to better enable clients to describe how their condition or being disabled affects daily life. A related recommendation suggests adding information on the reliability criteria to the form and to communications more generally.

37. The current application form reflects years of development and careful balancing of client needs and decision-making requirements. Since ADP’s launch, it has been refined based on feedback. Decisions on its format and content were informed by extensive research and aimed to address criticisms of the PIP application. Although this increased the form’s length, it was considered a worthwhile compromise to ensure decision makers have the information needed for accurate determinations, particularly given the removal of DWP-style assessments.

38. The Report provides valuable insights into clients’ experiences of completing the form, and the Scottish Government agrees it should be reviewed. This work will require significant time and resources, and Social Security Scotland will consider how it can be delivered within existing programmes.

39. The final recommendation in this section proposes automatically granting ADP entitlement to clients who meet certain conditions outside the eligibility framework or who receive other forms of support. It also suggests removing the three-month qualifying period for these people. This would represent a significant departure from the current process, which, except for terminal illness cases, requires a decision based on the application form.

40. The current process uses application information to assess the impact of a client’s condition. The proposed approach would rely on other indicators, such as receipt of Independent Living Fund (ILF) support for employing carers or personal assistants. Implementing this would require careful consideration to ensure these indicators reliably reflect the impact of disability in relation to ADP eligibility. Research would be needed to identify suitable criteria and assess implications for clients who still need to apply. This work must be completed before the Scottish Government can decide whether to proceed. Additionally, parity across other disability assistance forms that are open to new applications (CDP and PADP) would need to be maintained.

41. The recommendation to remove the qualifying period may reflect a misunderstanding among clients and stakeholders. The rule requires that needs arising from disability have existed for at least three months before entitlement, as ADP is intended for long-term conditions. However, a diagnosis is not required during that period. The policy recognises that people may experience symptoms before diagnosis and allows entitlement to be backdated to symptom onset.

42. For example, a client may have been experiencing pain and fatigue, which limits their mobility, for two months before they are diagnosed with Rheumatoid Arthritis. Applying when they are diagnosed, the client’s entitlement would start one month later. This is because the three-month qualifying period is satisfied, taking into account the two months pre-diagnosis.

43. Feedback from stakeholders suggests they assume the client would need to wait a full three months after diagnosis for entitlement to begin. This indicates that clients may not realise they can explain in the application form how long they have been affected prior to diagnosis. Further user research will be undertaken to confirm this and inform an assessment of the value of this part of the proposal. Meanwhile Social Security Scotland will continue to look for opportunities to maximise understanding of this point.

Not implementing

44. There are three recommendations in this section that the Scottish Government does not intend to implement, all relating to re-determinations.

45. The first seeks to reduce the risk of a re-determination producing a less favourable outcome by allowing only specific elements of the decision to be reviewed. A re-determination is designed to review the entire decision, ensuring clients receive their full entitlement. This approach reduces the need for appeals. Limiting the re-determination to certain elements could result in clients not receiving everything they are entitled to, and they only have one opportunity for Social Security Scotland to reconsider their award. While concerns about reductions are understandable, the Scottish Government’s commitment to robust, accurate decision-making is best achieved by maintaining the current process. Social Security Scotland has recently updated letters to make clear that an award may increase, stay the same, or decrease following a re-determination.

46. Secondly, the Report also recommends improving re-determination timescales. The current 56-day timescale for disability benefit re-determinations, set in legislation, was informed by the 2016 Consultation on Social Security in Scotland and feedback from Experience Panels. It balances the need for timely payments with the time required to make accurate decisions and gather supporting information.

47. Performance against this timescale is strong, with around 95% of re-determinations completed within 56 days in the latest quarter. When the period lapses, Social Security Scotland contacts clients to ask whether they wish to continue or proceed to appeal. Since ADP launched, only 1% of clients have chosen to appeal at this stage. This suggests the current timescale works well. Reducing it could compromise accuracy by limiting time for information gathering and divert resources from other decision-making processes.

48. The third recommendation proposes automatically providing Short Term Assistance (STA) to clients challenging a decision, with an option to opt out. Currently, clients can request STA by ticking a box on their re-determination or appeal form, or by calling Social Security Scotland at any point during the process. Awards are backdated to the start of the challenge. The Scottish Government believes this approach supports flexibility and client choice. Work with stakeholders will continue to raise awareness of STA, an option not available elsewhere in the UK, and its ease of access.

A Learning System

Work beginning within three months

49. This section includes five proposals for continuous improvement, two of which will be implemented. The first recommends that Social Security Scotland review its inclusive communication practices to ensure there are no barriers for people with communication needs applying for ADP. In addition to the existing inclusive communication hub and learning sessions, Social Security Scotland will soon launch an Inclusive Communication Pack to help colleagues embed inclusive practices in service delivery. Work will also continue with the Stakeholder and Partner Engagement Team, via the Operational Reference Group, to understand the needs of diverse clients and build an inclusive evidence base. This evidence will capture client experiences, helping to identify and remove barriers.

50. The second pertains to staff training surrounding stigma. All Social Security Scotland staff who interact with clients receive training about benefit stigma as part of their induction, reflecting the organisation’s commitment to understanding issues affecting people applying for support. The Scottish Government’s Disability Equality Plan 2025 includes a strategic objective to improve disability competence across the organisation. An intersectional approach will be taken, with projects building capacity around stigma—particularly as it relates to poverty, inequality, race, gender identity, and disability. Social Security Scotland and the Social Security Directorate will contribute to this work to deliver the Report’s recommendation on stigma training.

Not implementing

51. There are three recommendations in this section which will not be implemented at this time.

52. The first is to translate the full suite of client guidance into Braille, British Sign Language (BSL), Easy Read, and other accessible formats. Social Security Scotland already provides an ADP factsheet with all essential information in a range of formats, including BSL, Easy Read, and multiple languages. Stakeholder engagement indicates that organisations prefer to produce their own tailored materials when needed. This will, however, remain under review through ongoing engagement.

53. Secondly, the Report recommends drawing greater attention to the option for determination and re-determination letters to be translated into alternative languages. Current demand for this service, highlighted in the ADP application form, suggests good awareness, but this will also be kept under review.

54. A third recommendation proposes providing ADP clients with a single point of contact throughout their application and re-determination journeys. As ADP is a lifelong benefit, clients interact with Social Security Scotland at many points over time. These touchpoints involve tasks carried out by different teams to ensure efficiency and expertise. This approach also safeguards the integrity of the re-determination process, as staff handling re-determinations have had no prior involvement in the original application.

A Better Future

55. This theme contains the Report’s most significant recommendations. Most relate to ADP entitlement criteria, including activities and descriptors. While the current Scottish Government recognises the importance of continuing to improve disability benefits and has commissioned the further work outlined, it will be for the next Scottish Government to respond following the election to the Scottish Parliament in May 2026.

56. To inform consideration of the recommendations however, we have carried out initial analysis of the potential costs of implementing those which are likely to lead to increased entitlement to ADP. We focused on the proposals to remove the 28‑day hospital rule, introduce certain automatic entitlements, create a new entitlement category linked to substantial risk, and widen eligibility for the mobility component. Such analysis helps us understand what these proposals might mean in practice, both for the people who rely on Adult Disability Payment and for the wider social security system.

57. Implementing these four recommendations could cost around £770 million per year if introduced from 2026/27, rising to more than £1 billion by 2029/30. These estimates highlight the scale of ambition behind the Review’s proposals while also illustrating the significant level of investment required to deliver them safely and sustainably. The recommendation to expand eligibility for the mobility component of Adult Disability Payment could lead to around two thirds of these estimated costs, particularly if more people received a higher mobility award. There are numerous ways in which the eligibility framework could be changed in order to deliver these recommendations, and the costs could vary significantly depending on how and when they are implemented.

58. Spending on disability assistance can change over time due to a range of factors, including how demographic trends influence overall demand for support, as well as how the award levels people receive change over time. It is therefore essential that any future changes are based on the best available evidence and developed in a way that protects the sustainability of Scotland’s social security system.

Considering further

59. The Scottish Government’s top priority when devolving disability benefits was the safe and secure transfer of people’s entitlement from the DWP to Social Security Scotland. Central to achieving this was introducing ADP with entitlement criteria largely aligned to PIP. Having been in delivery for over three years, and with case transfer complete, now is the time to consider what disabled people need ADP to become in the future.

60. Experience shows that this kind of reform cannot be achieved quickly. The wholesale modernisation of ADP, as recommended in the Report, will require extensive policy development, consultation, user research, and legislative reform. In many cases changes will require significant ongoing expenditure. This is further complicated by the limits of the current constitutional settlement, which requires negotiation with the UK Government on interactions between ADP and reserved benefits. Additionally, any technical or process changes needed by Social Security Scotland must be planned well in advance due to existing delivery schedules. These are not reasons to avoid the challenge, but transparency is essential about the scale of public investment required.