Disability benefits - supporting information: qualitative research

6. Conclusions

In this concluding chapter, we set out the findings in relation to each of the research questions before providing areas for consideration and a list of recommendations.

Findings on the research questions

Question 1: Do applicants understand what supporting information they should or could be providing to support the decision-making process as much as possible?

It is clear that many applicants do not fully understand what supporting information they should or could be providing. It is a common assumption that some sort of medical "evidence" will be required and so there are applicants who do provide that. Some applicants might not have access to medical information. Due to the assumption that some sort of medical information is required, this can lead them to being unsure about how to proceed and, in turn, not submitting supporting information from other professionals that might be equally or more helpful.

For those who are unsure what to do, phone calls with Case Managers are very helpful in clarifying what is required. This reinforces the importance of Case Managers having a good understanding of supporting information and therefore being clear on exactly what is required.

There is scope to communicate more clearly to applicants and potential applicants that supporting information is needed, what form it can take, and that it may speed up the decision if it is provided with the application.

Only those who had submitted an application were included in the research. It is worth noting that many of the barriers to supplying supporting information, and misunderstandings about what could be submitted, may have deterred others from making an application at all.

Question 2: Do applicants feel that their supporting information has been considered fairly?

Successful applicants did feel that their supporting information had been considered fairly. They explained that this was because they received an award which they felt they deserved and/or because the letter detailing the reasons for the decision showed that all their information had been considered thoroughly.

Some unsuccessful applicants did not think their information had been considered fairly, for example, they suggested that they may have been unfairly disadvantaged by not being able to provide supporting information from a health professional and having to provide it from their wider support network instead. They felt this was not given the same consideration that a letter from a health professional would have been.

Question 3: What impact does supporting information have on Case Managers' decision-making process?

Case Managers generally see supporting information as important to decision-making, although the impact varies depending on the application being considered. It has more of an impact if the application form lacks detail or if the individual has a less common condition or a complex condition with which staff are less familiar.

Fluctuating conditions (particularly fluctuating mental health conditions) were also mentioned as the impact on an individual can vary day by day: this can make decision-making more difficult as it can be harder to know how often something happens, or whether someone's condition may be generally improving/deteriorating which may make a difference to the award decision. In addition to establishing entitlement, supporting information can also be important in helping decide on the appropriate level of award and on the review period.

However, where the individual has supplied detailed information in the application form, supporting information seems to play less of a role in decision-making. This was because Case Managers felt that the application form contained sufficient information about the impacts of an individual's condition in order to allow them to make an informed decision. This is in keeping with Case Managers approaching applications from a position of trust (see further details in the Logic Model in Appendix 2).

The quality of supporting information was seen as more important than the quantity. CDP Case Managers mentioned that education plans and ASD diagnostic reports were particularly useful in decision-making.

Supporting information from an individual's wider support network was seen as especially helpful when there was scant information on the application form.

Question 4: Is the process of requesting and obtaining supportinginformation done in line with policy principles?

From the way staff described their approach and their interactions with applicants, it was apparent that they are acting in a way that reflects the Social Security Scotland core principles of dignity, fairness, and respect. They clearly saw their role as supporting disabled people who met the eligibility criteria, rather than being a 'gatekeeper' to an award or an 'investigator' of someone's eligibility. Staff referred to applicants in a respectful way that demonstrated they were starting from a position of trust. They sensitively worded conversations with applicants about supporting information to gauge whether they were happy and able to provide any themselves, and to avoid any undue stress. Staff were very clear that they did not need to obtain supporting information to support everything in the application form.

As highlighted in Chapters 4 and 5, there were areas where some staff behaviours and views were not fully in keeping with the policy commitments. This included when they referred to supporting information as 'evidence' or 'proof', and confusion about whether 'equal weight' was still applicable (i.e. whether staff should be giving equal weight to different types of supporting information). Though for the former point, it should be noted that staff did acknowledge that the language concerning supporting information as 'evidence' and 'proof' is not in line with the policy commitment. There was also a suggestion that it is not always easy, in practice, for staff to take a position of trust. This is because there is a tension between requiring supporting information to support the decision-making process, and trusting the applicant where information has not been 'confirmed' by another party. While these are important policy commitments, staff who held these views did not appear to be handling cases in a markedly different way to their colleagues, and they still appeared to be taking a person-centred and supportive approach.

Applicants were generally extremely positive about their interactions with staff. They felt they had been treated with dignity, fairness, and respect. Their experience had a positive impact on their perceptions of Social Security Scotland, their likelihood to contact them and their likelihood to apply for other benefits in the future. Successful applicants with experience of applying for disability benefits administered by DWP were overwhelmingly positive about their experience of interacting with Social Security Scotland.

The main issue affecting applicants' satisfaction are the delays that Social Security Scotland encounter in obtaining supporting information from professionals on their behalf. This creates a bottleneck in the whole system.

Additional insights on enablers and barriers to supplying supporting information

The interviews with applicants, Social Security Scotland staff and Third Sector staff shed light on a number of factors which appeared to enable applicants to provide supporting information, and factors which appeared to be barriers.

The main factors which made it easier for applicants were:

• Having experience of similar administrative tasks, often through work, or having someone in their household who had this experience.
• Being confident online and technologically literate or having someone in their household who was.
• Having supporting information to hand.
• Receiving support from Case Managers over the phone.

The main factors which made it more difficult for applicants were:

• Not realising that they had been asked to provide any supporting information.
• Not having a clear understanding of the different types of supporting information that can be submitted.
• Not realising that it would likely speed up their application if they provided supporting information at the start.
• Not being able to access a GP or not having seen a health professional. This could be due to difficulties getting an appointment or because of accessibility issues relating to the disability or health condition.
• The perception that not having a diagnosis would mean they would not be able to supply supporting information.

Staff also highlighted other groups who were more likely to struggle with providing supporting information and/or understanding what is required: people with severe mental health difficulties; people with addictions; those who experience difficulties completing tasks because of poor physical or mental health; the Gypsy/Traveller community; some religious communities (particularly where women might be less likely to access a GP); homeless people; prison leavers; people with little or no English; and people with low levels of literacy.

Recommendations and areas for consideration for the Scottish Government and Social Security Scotland

The following recommendations and areas for consideration come predominantly from applicants and Social Security Scotland staff themselves. Suggestions from the research team are reflections on what applicants and staff told us (and are identified as such). They are, broadly speaking, presented in order of importance. This is based on what we judge will have the biggest impact on the applicant experience.

Reduce delays in obtaining supporting information from professionals

The delays experienced by Social Security Scotland staff in obtaining supporting information from professionals, and GPs in particular, was the main issue affecting applicant satisfaction with the process. It was also one of the biggest frustrations for staff because it creates a bottleneck in the system and increases processing times. We recommend that the Scottish Government and Social Security Scotland work with GPs, the NHS and Local Authorities to find ways to ensure that supporting information requests are responded to more quickly. We recognise that these organisations face considerable pressures and making progress on this will not be straightforward.

On a practical level, providing GP and NHS staff with training on the SCI Gateway system will help. This is the secure email system used to communicate with GPs and the NHS. However, not all relevant staff know how to use the system.

Clarify the guidance on supporting information for applicants

Many applicants do not fully understand what supporting information they should or could be providing. We recommend reviewing the guidance included in the application form and elsewhere with the aim of clarifying:

• What supporting information to include, who it can come from, and what is 'required' – possibly in a separate guidance document.
• That help is available if someone is unsure what supporting information to provide, for example, from Client Support Advisors working in local delivery, Case Managers, and Third Sector organisations – all important enablers to providing supporting information.
• That, ideally, supporting information should be provided with the application and that this will likely speed up the process.
• That, ideally, one piece of supporting information from a professional should be provided.
• That supporting information can also be provided from the individual's wider support network.
• That Social Security Scotland can obtain supporting information on behalf of applicants, however, if individuals are able to provide this themselves then this will likely speed up their application.
• That photos of the applicant or child to show their condition should not be submitted (at the time of interviews, these could not be used).
• That an award can be made in the absence of a diagnosis (whether or not a formal diagnosis is available is irrelevant to the decision-making process).
• That, if there is good reason why an individual cannot provide supporting information, Social Security Scotland have discretion to make an award. Good reasons might include, for example, not being able to access a healthcare professional due to their condition or due to current waiting times.

It should be noted that most of these points are already covered in the guidance within the application form. However, some applicants were unclear about, or had misunderstandings about, these points which suggests there is a need to make the guidance clearer.

In relation to the point about Social Security Scotland being able to obtain supporting information on an individual's behalf, there is a tricky balance to be struck. It is important to encourage those who are able to obtain and provide supporting information themselves to do so, while making it clear to those who would have difficulty, that Social Security Scotland can contact professionals and request it for them. The best approach may be to emphasise that, if individuals can provide supporting information themselves, this will significantly speed up the processing of their application.

There is an even trickier balance to be struck in relation to the point about Social Security Scotland having discretion to make an award if there is good reason why no supporting information can be provided. The best approach here may be to advise potential applicants to contact Social Security Scotland for advice.

We also recommend revising the application form questions, taking into account the common 'gaps' that Case Managers are seeking supporting information to fill, such as specific details around mobility or night-time needs. This might involve changing existing questions and/or adding new ones. (Research team suggestion.)

More training and guidance for Case Managers on what to do if there is no supporting information with an application

There should be more of a focus in initial training on what to do if there is no supporting information with an application and how to go about obtaining it. Staff reported that the example cases they were given in their initial training all had supporting information provided whereas, in practice, most applications arrive with no supporting information. They also suggested that the decision-making guidance on this could be made clearer.

There should also be more guidance on what supporting information is sufficient. Senior staff said that even experienced Case Managers still tended to ask about this. Clearly, what is 'sufficient' will vary depending on the case, and staff have the discretion to make an award with no supporting information, but examples of what would be sufficient in different situations would be helpful.

Clarification of some key issues for Case Managers

There were a few key issues where at least some Case Managers had misunderstandings or were unclear what the position was. We recommend:

• Clarifying that the decision-making guidance on giving equal consideration to supporting information from different sources is not superseded by the requirement to have one piece of supporting information from a professional. Some ADP Case Managers thought that this was the case.
• Addressing the bias towards supporting information from professionals, and medical professionals in particular, that was evident among some Case Managers. Decision Team Managers talked about this sometimes being an 'unconscious bias'. This should be addressed in initial training, on-going training and in the decision-making guidance. CDP Case Managers talked about the long waiting lists for CAMHS appointments. This has led to them contacting a wider range of professionals (often from education) who can supply valuable supporting information. This could be used as an example. (Research team suggestion.)
• Addressing questions around the tension between a position of trust and the need to seek more clarification and additional information in some cases.

Improvements to Social Security Scotland internal systems

There were a number of suggestions for improving systems so they do more to help Case Managers obtain supporting information and track the progress of requests. Suggestions included:

• Developing a system that would allow more direct contact with professionals in the way that email does. This, in part, stems from the issues mentioned above with SCI Gateway.
• Adding a free text box for CDP staff to ask bespoke questions of professionals. CDP Case Managers are required to choose questions from a drop-down menu. Being unable to write their own questions means they often do not receive the exact information back from professionals that would aid their decision-making. ADP Case Managers said they do not use many of the pre-written questions, but they have a free text box that allows them to fully articulate what information they require.
• Improving the visibility of the status of supporting information requests for Case Managers (given some requests are done in systems they cannot access themselves).

More training for Client Support Advisors and Third Sector staff

Client Support Advisors in local delivery said the training they had received on 'a day in the life of a Case Manager' was very useful in helping them to understand the importance of supporting information. This session involved being told about supporting information from a Case Manager's point of view, among other aspects of their job. It was suggested that this course should be a requirement for new joiners. A further suggestion was that Client Support Advisors in local delivery should have the chance to practice uploading documents before meeting applicants for the first time.

More guidance and training should be provided to Third Sector organisations who might support applicants with their applications. This was something that the Third Sector staff we spoke to requested. They specifically wanted to better understand the role that supporting information plays in decision-making. Raising awareness of the 'day in the life of a Case Manager' training would help in this regard. The guidance/training could also address some of the areas that Third Sector staff appeared to be less clear about: that Social Security Scotland is asking for one piece of supporting information from a professional; that an additional written statement produced by an applicant themselves is not considered supporting information; and that GPs do not need to be contacted in all cases.

Improvements to the decision-making guidance

The decision-making guidance is regularly updated to address gaps that have been identified, to improve clarity, and to reflect changes in policy or processes. Case Managers frequently mentioned referring to the guidance. They also pointed out areas where they thought the guidance was not clear enough or where there were gaps in it. However, none mentioned using the feedback function that exists for staff to suggest improvements/point out gaps. Raising awareness of this function, and ensuring that staff feel empowered to use it, should help improve the guidance further.

Ensuring consistency between teams

Consider carrying out regular calibration exercises to identify the extent of any inconsistencies between teams. This recommendation came directly from a Decision Team Manager. Other staff who had moved teams also talked about inconsistencies. Staff felt that the following would help to improve consistency across teams:

• The introduction of a quality assurance framework for decision-making.
• The introduction of a separate quality assurance team.

Decision Team Managers, who are responsible for quality assurance, felt they would benefit from more training on this aspect of their role.

Case Managers also suggested that more opportunities for staff to learn from each other would help improve consistency. This links to another finding: that Case Managers are somewhat siloed in their individual teams and there is little interaction between teams at that level. They speculated that this was because most Case Managers had been trained remotely and then started working in the office while Covid-19 restrictions were still in place. This meant that teams did not mix and talk to each other about cases in the way that they might normally have done. We recommend encouraging more interaction between teams at Case Manager level.

Sharing information on re-determinations and appeals with Case Managers

Senior staff generally felt that the majority of Case Managers understand how to use supporting information and are making the right decisions in line with the decision-making guidance. Nonetheless, to increase the number of 'right first time' decisions, there was a suggestion that information on re-determinations and appeals should be shared internally, including the reasons for decisions. This would help staff understand where and why there are queries about decisions.

Supporting Decision Team Managers to implement policy changes

Decision Team Managers felt they would benefit from more time to keep up with policy changes themselves, as well as training on how best to keep Case Managers up-to-date with changes and how to implement them.

Immediate checks on whether an application includes supporting information

Case Managers reported that most applications arrive without any supporting information. They suggested 'triaging' cases for supporting information as they come in and confirmed that this was already being piloted. The pilot involves cases being assessed by a Case Manager before being passed to the decision-making Case Manager so that, by the time they are reviewing the case, they may have received the supporting information or are, at least, partway through the waiting time.

An online tracker to show applicants what stage their application is at

Some applicants indicated that they were quite anxious while they waited to hear the outcome of their application and a tracker should provide reassurance in most cases. It could detail various stages, including whether supporting information had been received by Case Managers.

Review the wording of decision letters to unsuccessful applicants

Consider whether the wording of letters to unsuccessful applicants could set out the reasons for the decision more clearly (research team suggestion). While we did not probe on the content of the decision letters in our interviews with applicants, the unsuccessful applicants we spoke to appeared unclear on the reasons why an award had not been made. Being clear about the reasons may help unsuccessful applicants feel that their case had, at least, been thoroughly considered.

Using Emergency Care Records as supporting information

Using a document like a 'Summary Care Record' or 'Emergency Care Record' could be very beneficial as supporting information because they could be accessed quickly and easily. The former is used in England and the latter in Scotland. Both are short reports that summarise a person's current conditions and medications. They can be accessed by staff other than doctors as they are designed so paramedics can easily access this information. A Case Manager who previously worked for DWP spoke of how useful Summary Care Records were when processing PIP applications. Staff who were aware of Emergency Care Records in Scotland said there is work being done to get a data sharing agreement in place so that these can be used as supporting information.

Improving the system for uploading documents

Applicants were generally very happy with the online system for uploading supporting information documents. They said it was convenient and easy to use. However, they suggested a couple of improvements:

• Being able to upload several documents at once in a zipped folder.
• It being clear that they can upload additional supporting information that arrives after the original supporting information has been submitted (those that raised this were not aware this is possible).

Improving Client Support Advisors' devices

Local delivery Client Support Advisors were very clear that the main process issue for them was struggling to photograph supporting information using their work laptops. While they do have work phones and tablets, they currently do not allow for photos to be taken and uploaded securely from them. They suggested that better tablets or phones would save time and make the process easier for them and for applicants, and avoid blurry or partial documents accidentally being uploaded.

To support applicants to upload information, Client Support Advisors said it would be helpful if they were able to share a direct link to the Social Security Scotland portal. This would overcome the current difficulty of having to read out the address and be sure applicants have accessed it successfully.