People with communication needs and the Scottish social security system: fulfilling the expectations of ‘Our Charter’
The Scottish Commission on Social Security's report on the experiences of individuals with communication needs in accessing the Scottish social security system.
This is our first report under our function to review whether people are receiving the service that the Social Security Charter expects.
Contents
4. Issues with the application process
Clear and accessible application processes are an important part of the social security system as outlined in ‘Our Charter’. Social Security Scotland has prioritised that ‘processes that work’ should include a supportive application process that will ensure people can apply in ways that suit their needs. Are the aims reflected in the experiences of people with communication needs?
Relevant Charter expectations
A people’s service
Social Security Scotland and the Scottish Government will:
- be patient, kind and consider how you might feel
- support you through your application, keeping you updated and explaining what will happen and why.
- refer you to independent advice and support if you want extra help with your application or appeal. You are also entitled to ask someone that you know to support you.
- make decisions in a way that is consistent and accurate – and aim to get them right first time
Processes that work
Social Security Scotland and the Scottish Government will:
- recognise that your time is precious and handle your application and enquiries as quickly as we can.
- ensure that disabled people who need help with the application process can get independent advocacy.
The majority of Social Security Scotland benefits have an application process, through which individuals apply to have their entitlement to benefits determined.1Benefits such as the Carer’s Allowance Supplement and Winter Heating Payment, are paid if the claimant get another qualifying benefit, without needing to apply.
As the research was undertaken during the process of transferring cases from the Department for Work and Pensions,2For example, “Management information at end November 2024 shows that there had been 323,500 clients from the Department of Work and Pensions who had been selected for transfer to Adult Disability Payment and had their case data sent to Social Security Scotland as part of this case transfer process… Social Security Scotland has now completed the case transfer process for 76% of those who were in receipt of Personal Independence Payment.” Social Security Scotland – Adult Disability Payment: high level statistics to 31 October 2024 some participants may not have been through an application process. There was, however, some helpful feedback from those who had experienced applying for a Scottish benefit.
4.1 The current evidence base
The client survey data noted that 85% of those with communication needs rated their experience of the application process as ‘good or ‘very good’ compared to 93% of those without communication needs.
People with communication needs were less likely than those without such needs to agree that the application process was clear (83% compared to 93%), the application process asked only relevant questions (82% compared to 93%) and that it did not take too long (77% compared to 93%).
4.2 Overall application experiences
Focus group participants reported feeling more supported when submitting their applications and generally found this to be a more dignified process, noting this as a welcome change from their experiences with the Department for Work and Pensions services.
“More compassionate and patient than previous engagements with the Department for Work and Pensions.” Focus group participant (client)
“The nature of the questions being asked is clearer and less intrusive [than with the Department for Work and Pensions].” Focus group participant (client)
Some participants acknowledged improvements in the process, noting positive changes to the application form:
“Forms for disability benefits make it a much easier process – it has certainly been simplified and it’s been improved, certainly compared to what we had previously.” Focus group participant (client)
However, the length and complexity of the online application form presented challenges. For example, participants found it unclear that the form had to be saved manually, and the requirement to fill in mandatory fields could be confusing. Inserting placeholder information and returning later was noted as potentially difficult for individuals with specific communication needs. Some participants said that the volume of information provided made it unclear what to focus on.
The overall size and scope of the application form in particular was noted as lengthy and complex for those with communication barriers.
Participants expressed concerns about the overall quality of communication, noting:
“Communication is poor with letters of entitlement sometimes arriving very late.” Focus group participant (client)
In relation to telephone contact, participants highlighted the professionalism of the call handlers, noting:
“Call handlers are very helpful and understanding.” Focus group participant (client)
“Call handlers are extremely pleasant and understanding.” Focus group participant (client)
However, as discussed earlier, some participants also mentioned having to repeat information.
“People have reported difficulties when they don’t speak to the same person across multiple calls, leading to repeated explanations and information sharing. Navigating the initial phone menus can be time-consuming, which can pose a challenge.” Structured interview participant
One participant also mentioned the difficulty of having multiple queries dealt with in the same phone call. This can be more challenging for people who experience anxiety about their communication needs when making such a call.
“.. when you call Social Security Scotland with a query, you can only address one issue per call. This can slow down the process, as you may need to call again or be redirected, leading to an unspecified wait time. If advisers were able to address multiple questions in one call, it would speed things up” Structured interview participant
Participants also shared concerns about the Social Security Scotland website, stating:
“The Social Security Scotland website currently feels formal and bureaucratic, catering more to stakeholders than addressing the needs and preferences of young people.” Focus group participant (client)
It was noted that, at times, the initial letter of determination, at the end of the application process, is not provided in the necessary format, potentially leading to delays in lodging appeals. Some participants reported receiving their award in their bank account before the arrival of the award letter, leading to making additional calls for reassurance.
Participants also commented about the length of time it can take to get support arrangements (such as British Sign Language interpretation) in place, as discussed above. There was also a fear that this could have implications for the progress of someone’s application.
“Additional time is often required, such as waiting for alternative format information, which can cause delays in accessing other benefits or assistance. Occasionally, the initial determination letter is not sent in the required format, delaying the possibility of appeals or other actions.” Structured interview participant
“BSL or hands-on communicators are hard to access so [access to] benefits are delayed further”. Focus group participant (client)
Social Security Scotland has written guidance on identifying sound reasons for applications or information submitted late for disability benefits which is publicly available on its website.5For example, Social Security Scotland – Child Disability Payment decision making guide – Late completion of application The guidance notes that individual circumstances will be considered in each case.
4.3 Awareness of and access to advocacy
To fulfil its statutory expectation “to ensure that independent advocacy services are available” under section 10 (2) of the Act, the Scottish Government funds an independent advocacy service, VoiceAbility. The service itself intends to support people to better engage with Social Security Scotland in terms of access, information, and assistance.
Participants, particularly those with learning disabilities, noted that advocacy helps to address their anxieties before any interaction with social security systems.
“People with learning disabilities may feel intimidated in [reviews or face to face determinations] settings, may forget to mention important details and may not fully understand decisions made or things communicated to them.” Focus group participant (client)
Participants also noted that this service remaining independent was important to them, “to make sure people felt supported to get full access to benefits they were entitled to”.
However, people with communication needs were often unaware that this support was available to them during the process. This concern has also been reflected in the findings of the interim review of Adult Disability Payment.7Independent Review of Adult Disability Payment – Interim Report
Participants generally felt that more should be done to promote the advocacy service to people with communication needs and that the starting point for this should be greater visibility of the service in communications received from Social Security Scotland.
4.4 Fulfilling charter expectations
Relevant charter expectations are highlighted in bold.
When compared to experiences of other benefits systems, people with communication needs highlighted that Social Security Scotland provided a greater level of support through the application process and various improvements whilst also noting that the volume of information required was significant. Participants suggested that improvements could be made in these processes, for example clearer direction that manual saving of application processes was required to save progress.
Participants raised concerns about the time taken to obtain support with their communication needs, such as receiving information in a format which is accessible to them. This could affect whether deadlines could be met and potentially their eventual entitlement.
Furthermore, participants often highlighted the amount of time they were required to invest in making an application, and that this did not recognise that your time is precious and they did not feel their enquiries were dealt with as quickly as possible. This was particularly raised in relation to call waiting times and the handling of consent for someone else to contact Social Security Scotland on their behalf.
Disabled people who need help with the application process can get independent advocacy and this was valued by participants. Whilst the contractual relationship is with the Scottish Government, it is also clear that Social Security Scotland could learn more from the information gathered by VoiceAbility in undertaking its independent advocacy role.
4.5 Recommendations
Recommendation 6: To ensure people with communications needs can access support from external organisations as quickly as possible, Social Security Scotland should work with stakeholders and partners to identify the causes of any delays and address them.
Recommendation 7: To gather evidence on people’s understanding and availability of advocacy support, Social Security Scotland should include awareness of and use of advocacy in its client survey and other research.