The Disability Assistance for Older People (Scotland) Regulations 2024: scrutiny report

Stakeholder organisations consulted by SCoSS, including Age Scotland and Alzheimer Scotland, noted the traditionally low take-up of social security payments by older people and referred to barriers to take-up by older people generally, noting the importance of targeted promotion that considered minority groups and people with cognitive impairments. Streamlining and simplifying the application process as much as possible would be welcomed by these organisations, paying regard to the potential for digital exclusion and signposting to advice and assistance services wherever practical.

Stakeholder organisations also referred to various concerns as potentially limiting Attendance Allowance (AA) take-up, noting principally that older people, working age people and younger people can face different challenges and therefore care must be taken when applying existing processes from one claimant group onto another. Barriers to claiming AA can include:

• Complexity of the claim form¹The possibility of finding claim forms overwhelming is noted in EQIA p. 11 & Fairer Scotland IA p. 3.
• Not understanding what supporting information is required²Noted by participants at Age Scotland events, 4 and 5 October 2023.
• Difficulty in accessing supporting information³Including specialist medical information from GPs and other registered medical professionals – Citizens Advice Scotland.
• Some may not have access to a support network to assist them⁴EQIA p. 11 & Fairer Scotland IA p. 3
• Some claimants may need more support than working age claimants in order to make a claim and complete the form, which may generate increased demand on Social Security Scotland⁵Noted by participants at Age Scotland events, 4 and 5 October 2023.
• Not knowing that the benefit exists, or that they might be eligible for it⁶Age Scotland, Benefit take-up and older people (ageuk.org.uk)
• Not knowing where to find advice and/or support⁷Age Scotland, Benefit take-up and older people (ageuk.org.uk) See also EQIA p. 12 referring to older people being disproportionately affected by social isolation, limiting their access to information.

The Scottish Government is required under the Social Security (Scotland) Act 2018 to promote the take-up of Scottish social security payments, and to lay before Parliament and publish regular strategies for doing so. The last strategy was published in October 2021⁸Social Security (Scotland) Act 2018: benefit take-up strategy – October 2021 and the next is required by 2026.⁹Social Security (Scotland) Act 2018 (legislation.gov.uk) section 9 (1)(c) The timeline for the third strategy was established pre-pandemic, and delays to the introduction of various Scottish social security payments¹⁰The Scottish replacements for Cold Weather Payment, Carer’s Allowance, Disability Living Assistance for Children, for example. were not envisaged or anticipated when it was set.

In February 2020 the introduction of the Scottish replacement for AA was expected to be delivered in 2021¹¹Social Security Programme- PMO – Business Cases – SSPBC Version 4 (www.gov.scot) but this was delayed until now. There might be considerable benefit, therefore, to re-examining the take-up strategy earlier than previously planned, to take into account social security payments such as PADP that have been introduced since October 2021.

Recommendation 2: The Scottish Government should consider bringing forward the 2026 take-up strategy to integrate the most recent benefits into the strategy as a whole.