Scottish Government Position Paper: Case Transfer
This paper is one of a series providing an update on our position on various matters relating to the development of the devolved social security benefits in Scotland.
The purpose of this paper is to set out our approach to transferring existing benefits cases from the Department for Work and Pensions (DWP) to our own agency Social Security Scotland. It explains the context of the existing systems in DWP from which cases must be transferred, and sets out our approach and plans for transfer.
There will be over 500,000 existing cases to be transferred from DWP once we have established the new devolved benefits. These are people in Scotland who already receive from DWP one or more of the benefits that are being devolved and is clearly a significant portion of Scotland's population.
Case transfer will start in 2020 after Disability Assistance for Children and Young People (DACYP) is delivered. This will replace DWP's Disability Living Allowance (DLA) for children. Case transfer for all existing in scope DWP cases is targeted to complete in 2024 with the majority being completed in 2023.
The scope of case transfers includes:-
- People in receipt of DLA for children from DWP, who will transfer onto DACYP;
- Adults aged 65 and over in receipt of DLA from DWP;
- Working age people in receipt of Personal Independence Payments (PIP) from DWP, who will transfer onto Disability Assistance for Working Age People (DAWAP);
- People in receipt of Carer's Allowance from DWP, who will transfer onto Carer's Assistance; and
- People in receipt of Attendance Allowance from DWP, who will transfer onto Disability Assistance for Older People (DAOP)
A transfer strategy for people in receipt of Industrial Injuries Disablement Benefit from DWP will be designed when plans for new claims for this benefit are more advanced: our position paper contains further details on our plans for this benefit. We are not proposing to transfer existing claims of Severe Disablement Allowance, for the reasons set out in our position paper.
Whilst we are building a different benefits system to meet the principles set out in the Social Security (Scotland) Act 2018, we propose to keep the components and financial values of the transferring benefits largely unchanged at the point of transfer. As the component parts of the new benefits are similar to the existing benefit this will reduce the case transfer risk.
We are committed to working with benefit recipients and stakeholders in the co-design of the case transfer processes. We have already conducted an online survey on case transfer with Experience Panel members, which was published on 27 February 2019 We have also engaged Experience Panel members throughout Scotland in a series of Focus Group discussions.
Discussions on case transfer have commenced with DWP.
People centred transfer principles
The benefits being transferred are critical for some of the most vulnerable people in our society. We are committed to working with existing benefit recipients and stakeholder organisations to ensure that we do not repeat the mistakes of previous benefit transfers. Our case transfer process will be based on a series of transfer principles which are important to existing benefit recipients.
We have completed an online survey which sought feedback from Experience Panel members on what aspects of case transfer were important to them. Further research with stakeholders and those with lived experience of the current system will be conducted to develop the case transfer principles.
Transfer Principle – Correct payment at the correct time
The most important case transfer principle to panel members was that they continue to receive the correct payments at the correct time. This aligns with previous research during the passage of the Social Security (Scotland) Act which indicated that a "safe and secure" transfer is a priority. The money that people receive from their benefits is important and not receiving a payment on time could cause financial difficulties – as one respondent pointed out, "People on benefits are already struggling. Stopping payments while they reapply or changeover will see them suffer more hardship. Many face hunger or worse." We will therefore design the case transfer process to ensure that people receive the right payments at the right time. This will include checks at the point of transfer, clients will receive the same amount for the Scottish benefit as they received for the corresponding UK benefit.
Transfer Principle – No re-applications
The House of Commons Work & Pensions Committee review of Universal Credit transfer was critical of the DWP policy to require applicants to submit a new claim. Clients have also advised us that re-applying for benefits is stressful – "the most distressing experience for claimants is reapplying for benefits they have already qualified for". We will not require clients to re-apply for their benefit as part of the case transfer. We will work with DWP to move clients automatically to Social Security Scotland and the corresponding new Scottish benefit.
Transfer Principle – No face to face DWP re-assessments
We have also listened to client feedback on reassessment – one respondent wrote "everyone fears face to face meetings. It causes unnecessary stress, worry and anxiety that could be completely avoided with a good application system." We therefore will ensure that no-one will be subject to a face to face re-assessment by DWP when new claims for PIP/Disability Assistance for Working Age People are open.
Transfer Principle – Complete as soon as possible
We expect to complete the case transfer by 2024, with the majority of case transfers being completed by 2023, though we will not do so if it creates unacceptable risks for clients. This will be subject to DWP agreeing to match our pace. If during the case transfer process we find that it is possible to accelerate the rate of case transfer, whilst still meeting the requirement that it is "safe and secure", then we will.
Client feedback is that the majority of people want cases transferred from DWP with a balance between speed and making sure there are no mistakes – as one respondent to the survey told us, "I would like to see the transfer done as fast as possible, but not if it means there could be issues with payments". We have two key dependencies in meeting the 2024 date:
- For each benefit, before we can transfer existing claims we first need to deliver our new claims/application service – we cannot transfer existing cases to the new benefit systems if they have not been built yet.
- We are dependent on DWP to work with us to plan and deliver the "safe and secure" transfer of existing cases.
Transfer Principle – Clear communication with clients
We will tell our clients the date their case will be transferred and will keep them informed at the various stages of the case transfer process. We are currently running Focus Group discussions on when, what and how we should communicate with clients during case transfer.
There have been a number of recent examples demonstrating the challenges of migrating benefits, such as the delays in the DLA to PIP migration, and the migration of legacy benefits to Universal Credit.
Case transfer is a complex undertaking. Detailed below are some of the inherent complexities of benefit transfers, including:-
- The original systems being migrated from (source systems) are often old and have been developed over many years, and have not been designed to export data;
- The source systems have many links to other systems, so the passing of information between the various benefit systems is complex and has been developed over many years;
- Documentation relating to changes to the source systems over the years may not have been kept up to date;
- The client data stored for the existing benefits may not be in the correct format for the new (target) systems. Only PIP data from DWP will be in the correct format. DLA child, Attendance Allowance and Carers Allowance run on old legacy DWP systems with data structures/content which will require significantly more transformation;
- Client data in the source systems may be missing or wrong;
- There may be very complex cases, albeit often impacting on only a small number of benefit recipients, which require high levels of manual intervention to deliver the benefit on the source system;
- The number of clients and amounts of data may be very large;
- The number of DWP staff who understand the source systems may be limited and/or fully occupied keeping it running for day to day operations;
- Even after extensive periods of testing, new systems often experience some form of "teething problems" after they are first launched. The new target systems are therefore subject to higher than normal levels of change in the period after they have been launched; and
- • The launch of new benefits places a heavy workload on frontline Social Security Scotland staff: learning how the new benefit works, how the new systems work, and dealing with new claims from clients. Transfer of existing client cases adds further work to already busy operational teams.
We will continue to work with existing clients and stakeholders in the Experience Panels. Focus Group sessions held in February will include research on:-
- how and when we should communicate with clients about the case transfer process;
- what data we should transfer from DWP;
- the sequence in which we transfer benefits; and
- how we select which clients transfer when.
This research is expected to be published in May 2019.
In parallel we will continue working with DWP to plan case transfer.
Head of Service Design for Disability and Carer's Benefits
4 Atlantic Quay,
70 York Street,
Glasgow, G2 8JX