Devolution of disability benefits: evaluation strategy

Evaluating the devolution of disability benefits

The devolved social security benefits represent an ambitious agenda for changing the benefit support that is made available to the people of Scotland. A previous evaluation strategy that focussed on our approach to evaluating the first tranche of devolved benefits was published in November 2019. This strategy builds on that work and outlines the approach to evaluating the policy impact of the devolution of disability benefits.

This strategy covers the three main types of Disability Assistance:

• Child Disability Payment, which will replace Disability Living Allowance for Children (DLA Child), is currently being piloted in three local authority areas and will be rolled out nationally in Autumn 2021 for new applications.
• Adult Disability Payment, which will replace Personal Independence Payment (PIP), will begin being piloted in Spring 2022, and will be rolled out nationally in Summer 2022 for new applications.
• Pension Age Disability Payment, which will replace Attendance Allowance in the future.

It also covers:

• The case transfer process of moving the disability benefits of Scottish clients currently administered by the Department for Work and Pensions to Social Security Scotland and onto the new equivalent forms of assistance.
• The Accessible Vehicles and Equipment Scheme, which replaces the UK Motability Scheme.
• Child Winter Heating Assistance, which is designed to help families of severely disabled children.

It does not cover:

• Severe Disablement Allowance - as it is a 'closed' benefit with no new applications. This benefit will be delivered by the Department for Work and Pensions for the foreseeable future.
• Employment-Injury Assistance - which will replace Industrial Injuries Disablement Benefit. The Scottish Government plans to undertake a consultation ahead of delivery which will inform detailed policy proposals.

Role of policy impact evaluation

Devolved benefits are being delivered in line with the Social Security Principles outlined in the Social Security (Scotland) Act 2018. Our Charter^[1] explains what the principles mean in practice and what people are entitled to expect from the Scottish Government and Social Security Scotland, and has a Measurement Framework^[2] that gathers information aginst these commitments.

Policy impact evaluation is the systematic assessment of a Government policy's design, implementation, and outcomes. In the context of social security, this involves understanding how a benefit is being implemented and what effects it has had, for whom and why.

Social security policy evaluations are one source of evidence that shows the contribution of benefits to delivering on the wider Social Security Principles and wider government objectives, particularly the effectiveness of policymaking processes, and whether social security has been an investment in people, helped to reduce poverty, and brought value for money.

The approach to providing disability benefits has been developed by listening to individuals who have a lived experience of the current social security system, and organisations representing disabled people or people with long-term health conditions. Policy impact evaluation projects will be developed with stakeholders and developed alongside the wider programme of engagement work by Social Security Scotland, which involves those with lived experience, in order to show whether the service has been designed with client needs in mind and delivered with dignity and respect.

Policy impact evaluation will also incorporate learning from other information sources and workstreams across the Scottish Government and Social Security Scotland to assess the effectiveness of benefit delivery from the policy view. This includes work underway to measure the take-up of Scottish social security benefits.

Comparisons with the approach to evaluating low-income and early carer benefits

Our published evaluation strategy outlined our evaluation approach for low-income and early carer benefits introduced up to 2020^[3]. It charted how each individual benefit would be evaluated using a theory of change, which can be used to investigate net impacts by exploring the causal chains thought to bring about change by an intervention^[4].

Logic models (similar to that in Annex A) were used to identify how the benefit itself, and the way the benefit was delivered, could be expected to achieve the expected short- and medium-term policy outcomes by documenting the causal steps that lead from one outcome to the other. They were also used to assess the likely contribution to wider social security and long-term government objectives.

The policy evaluations planned under this framework were started around 12 months after benefit launch, and made use of a range of data sources including Social Security Scotland data and bespoke commissioned research with applicants, clients and other key stakeholders. The findings from the evaluations published to date are available on the Scottish Government website^[5].

Though the theory of change approach, and relevant data sources, will be used as part of the evaluation approach to disability benefits, there are some fundamental differences in the way that disability benefits will be delivered that means the evaluation approach will have to be adapted.

Key considerations in evaluating disability benefits

Disability benefits are more complex to deliver than the first tranche of benefits for a number of reasons outlined below:

• They involve regular payments to individuals, who will have an ongoing relationship with Social Security Scotland.
• People's circumstances may well change during that relationship, requiring adjustments to their payments.
• Whereas establishing people's eligibility for the first tranche of benefits is relatively straightforward, to establish whether someone is eligible for a disability benefit is complex and will involve gathering supporting information and more sophisticated decision making.
• For the majority of the first tranche of benefits, people who are receiving them are usually getting them because they are already entitled to another benefit administered by the Department for Work and Pensions (DWP) - meaning that DWP has already established who they are. Some new applicants for disability benefits will not be getting any form of DWP support, meaning that Social Security Scotland will need to verify their identity.
• Social Security Scotland will also need to be able to deliver client consultations for Adult Disability Payment.
• As disability benefits are currently administered by DWP, the majority of those who will be receiving the new forms of assistance in the first few years will be clients whose awards have transferred from DWP rather than those who have made a new application directly to Social Security Scotland.
• The different forms of Disability Assistance are being launched in a phased way - with Child Disability Payment the first to pilot.

The initial priority is ensuring that clients transition safely and securely from DWP to Social Security Scotland, and continue to get the right payments at the right time. The new applications service will be launched before starting to transfer the disability benefits of existing Scottish clients from DWP to Social Security Scotland.

Given the priority of safe and secure transition, it is intended that eligibility criteria, rates and components of all forms of Disability Assistance will initially remain largely the same as the current equivalent UK disability benefits until after transition is complete^[6]. This means that policy changes have largely been focussed on the way that entitlement and awards are assessed, the way that the benefit is delivered and the way that benefit delivery is experienced by applicants and recipients.

As a result, the main focus of initial evaluation activity will be assessing the impact of these policy changes on clients and client outcomes, rather than assessing the impact of disability benefits generally. Therefore, it is not designed to look at questions of adequacy of payments, for example. However, where relevant, evaluation research will give an opportunity for clients to recount their experience of disability benefits generally, and the impact of disability benefits on their quality of life specifically. Disability Assistance, like all devolved benefits, is regarded as a human right by the Scottish Government. We are committed to ensuring that those who interact with the social security system are treated with fairness, dignity and respect and those who are entitled to social security are able to access it. Within this, the intention is to develop a 'person-centred approach', which treats clients as individuals, taking into account their personal circumstances and needs when making decisions on entitlement and awards^[7]. However, this will have to be delivered alongside the need to ensure that the benefit is delivered consistently and that people in comparable positions are treated similarly.

The larger levels of government investment; the complex nature of disability benefits delivery generally, and the client journey specifically; the case transfer process; the initial focus on changes to decision-making processes and benefit delivery; and the phased launch of the different forms of Disability Assistance, mean that the evaluation approach for disability benefits will also be more complex compared to the first wave of devolved benefits.