Proposed Policy Framework Part 2 - Total Mobility Scheme Review

The Total Mobility Scheme

4. Proposed Policy Framework for the Total Mobility Scheme part 2.

4.3 Entitlement

4.3.1 Current policy context

The entitlement provided by the Scheme is subsidised transport, usually provided by taxi operators. It is important that the cost of this transport is financially affordable and sustainable for local authorities and Land Transport NZ. The Scheme is a relatively high cost service, and local authorities adjust and limit entitlement through various mechanisms to ensure the Scheme operates within budget. These mechanisms include:

• establishing a fare subsidy (usually 50%);
• setting a minimum fare threshold;
• setting maximum subsidised fares;
• limiting trips (by way of voucher allocation and/or trip purpose);
• prohibiting travel outside town boundaries.

Local authorities may use all or some of these mechanisms, and this is reflected in varying rules relating to entitlement around the country. Scheme use is further limited by the lack of advertising of the Scheme (this is discussed further in section 4.5).

 

4.3.2 Key issues

The key issues relate to regional variability in the rules associated with the provision of the transport service with regard to the five areas outlined above (Section 4.3.1). These rules restrain the level of use of the Scheme by members, and largely function to manage local authority budgets.

Little is known about the travel behaviour of current Scheme members and the extent to which the level of entitlements provided are adequate to meet their needs. Data provided by local authorities indicate that the monthly average number of trips taken by Scheme members is low, and in many regions, it may be as low as two trips a month ³¹. This suggests that overall most Scheme members are very low users of the Scheme, and that there is a minority group of high users.

The reasons for low use (or high use) are unclear. They will however reflect local Scheme rules, and be heavily influenced by the cost of a taxi fare. Many Scheme members are likely to have low incomes, and will limit their own use of the Scheme accordingly ³². Some may not use it at all, as even with a 50% fare subsidy the costs may be prohibitive. Similarly, it is likely that many potentially eligible Scheme members may not apply to join the Scheme due to the cost of taxi fares.

Increasing the fare subsidy would increase the affordability of the Scheme for current members and may reduce financial barriers for potential members. However at this time the Ministry of Transport does not have data to estimate the extent to which the fare subsidy would need to be raised to bring it into a more affordable range for the latter group, nor the extent to which it would increase demand for the Scheme.

The following recommended improvements focus on improving the rules to increase the adequacy and over-riding purpose of the Scheme. It is expected that some rules can be nationally consistent (such as fare subsidy) while others will differ to take account of local topography, population and travel patterns and costs (such as maximum subsidised fares). However even with regard to the latter, decision-making can be based on a nationally consistent transparent method. Currently there is no such method.

Collectively these recommendations improve the adequacy, consistency, and sustainability and coverage of the Scheme (as shown on Appendix 7).

4.3.3 Recommended improvements

10. That the fare subsidy for the Total Mobility Scheme should be nationally consistent and standardised at 50%.

With regard to fare subsidy most local authorities provide a 50% fare subsidy, although in the recent past one or two have reduced it to a lower level near the end of the year to manage their budgets. For this reason it is recommended that it be fixed at a 50% minimum.

This proposed improvement was supported by 89% of the submissions. However as already noted, this subsidy level may be too low for some. Raising the fare subsidy to a higher level should be considered in the future.

11. That the Total Mobility Scheme has no minimum fare threshold.

Some regions require a minimum fare threshold before the subsidy is applicable. For instance, if a fare threshold were $5 the subsidy would only apply after the fare had reached this amount. This requirement penalises Scheme members who only ever need to make short trips in these regions and are therefore ineligible to receive a subsidised fare.

This proposed improvement was supported by 55% of submissions. Thirteen out of the fourteen local authorities that responded to this question, supported this proposed improvement. Transport operators were evenly divided in their views.

12. That local authorities determine maximum subsidised fares for the Total Mobility Scheme in negotiation with Land Transport NZ, taking into account the NZ Travel Survey, and review them annually.

Maximum subsidised fares are set by all but one local authority, and vary accordingly. There does not appear to be any consistent method for determining the maximum subsidised fare. However in order to reflect the proposed purpose of the Scheme, it is important that the maximum subsidised fare is established at a level that is adequate and appropriate for any town or region operating the Scheme.

A useful tool for providing guidance is the NZ Travel Survey. It provides average trip distances undertaken by householders for local trips, in specific towns and regions. It is recommended that maximum subsidised fares should be determined taking this data into account. Maximum subsidised fares could be determined within a range between the 75th and 95th percentile of trip distance averages for the region. These calculations are provided in Appendix 9.

The final determination of the maximum subsidised fare should be negotiated between the local authority and Land Transport NZ, taking into account other relevant factors such as local topography, population and budgets. Further, this figure should be reviewed annually to take account of changes in the CPI, and any new information provided by the NZ Travel Survey ³³.

Almost 80% of all submissions, and 50% of those from local authorities, supported a nationally consistent method for determining maximum subsidised fares.

13. That town boundary travel restrictions for the Total Mobility Scheme be removed and replaced with a maximum subsidised fare.

Most Schemes do not allow subsidised trips to be taken outside the town boundaries. To some extent this is reasonable and consistent with the proposed Scheme purpose, which limits subsidised travel to local trips. However this rule is unfair for people who live just beyond town boundaries, or need to travel to a destination just beyond town boundaries. It also prevents travel to nearby towns where distances are very small, but where many key services and activities may be located. This is a particular issue for small provincial or country towns. Accordingly it is recommended that town boundary travel restrictions should be removed, and that subsidised travel be limited by the maximum subsidised fare.

14. That the number of allocated subsidised trips for the Total Mobility Scheme take into account the self-assessed needs of individual Scheme members, and be adjusted by local authorities to manage their budgets, and negotiated with Land Transport NZ.

This approach is not entirely inconsistent with the current practice of some local authorities. However it will also be important to ensure the level of trip allocation is adequate to reflect the Scheme purpose, and is reasonably consistent with the allocation level provided in other regions. To ensure this, the local level of trip allocation should be subject to negotiation with Land Transport NZ, and monitored.

Through this mechanism the Scheme can be responsive to different levels of need for subsidised trips (e.g. occasional, weekly or daily) rather than the allocation of a fixed amount at fixed intervals. Further, this is an important mechanism for local authorities to control the budget and constrain spending.

Invercargill City Council successfully uses this mechanism to manage its Scheme budget. It uses a guided self-assessment process ³⁴ to nominate the (realistic) amount of subsidised trips required, and calculates the extent to which its allocated budget can meet this demand. If it cannot, it will reduce every member's allocation by the same percentage to stay within budget, and inform members of their allocation. ³⁵ More information about the Southland (Invercargill) Scheme is provided in Appendix 6.

The extent to which this specific method can be successfully applied to all Schemes has not been tested, however it is a promising approach and could be used as a basis upon which individual local authorities and Land Transport NZ could negotiate a locally appropriate variant of this method.

The proposed improvement to develop a nationally consistent method for determining the number of vouchers allocated to each person was supported by 51% of submissions. Seven of the fourteen local authorities that responded to this proposal, supported a national method for allocating trips. Some noted the importance of this mechanism for budgetary control.

15. That there are no restrictions on the purpose of the trip for the Total Mobility Scheme.

In some regions allocated trips may be limited to specific trip purposes. This prevents Scheme members from deciding on the types of trips for which they will use their vouchers. This is inconsistent with the proposed purpose and central tenet of the Scheme that is concerned with providing access to subsidised transport, rather than prescribing appropriate or inappropriate destinations. However it is not intended that the Scheme should be a substitute for transport services that should more appropriately be the responsibility of other government agencies, such as those in the health sector or ACC.

This proposed improvement was supported by 80% of submissions.

4.4 Assessment services

4.4.1 Current policy context

Assessment of eligibility for the Total Mobility Scheme is most commonly undertaken by voluntary agencies in the disability sector. Often there are a number of agencies in a region providing assessments, covering a broad range of impairment types ³⁶. The involvement of the voluntary sector in providing assessment services has been a characteristic of the Scheme since its inception.

In some regions general practitioners ³⁷ and/or professional assessors may be contracted by the local authority to provide assessments. This may be instead of or in conjunction with, assessments by voluntary agencies.³⁸ At the other end of the spectrum, there is one local authority that provides for self-assessment of eligibility by potential Scheme members, if it is accompanied with an endorsement by an appropriate voluntary sector disability agency.

Assessment services directly from the potential Scheme members. An agency may require potential Scheme members to join and pay annual membership fees, or alternatively require payment of an assessment fee. Some agencies require both a membership fee and an assessment fee. For some Scheme members the agency membership requirement may be quite acceptable, and provide them with access to other useful services provided by the agency.

4.4.2 Key issues

The key issues primarily relate to the inconsistent application of the eligibility criteria between regions, and the lack of clear accountability arrangements between local authorities and voluntary sector assessment agencies. The Scheme can also create potentially high workloads for assessment agencies, with little or no financial recompense. For some Scheme members the requirement that they must join an agency and pay an associated membership fee is undesirable.

In regions that only engage general practitioners to provide assessments, this may create a cost barrier for some potential Scheme members. It may also be unacceptable to some members of the disability sector who do not consider disability should be viewed as a medical condition.

The following recommended improvements focus on supporting the consistent application of the eligibility criteria by assessment agencies, and implementing arrangements to improve accountability between assessment agencies and local authorities. They also clarify the relationships (financial and membership) between applicants and assessment agencies. Collectively these recommendations improve the adequacy, consistency and sustainability (see Appendix 7).

4.4.3 Recommended improvements

16. That Land Transport NZ develop guidelines for contracts between local authorities and assessment agencies to ensure high quality and consistent assessments.
17. That local authorities enter into contracts with assessment agencies, aligned with the guidelines produced by Land Transport NZ.

These recommendations will improve consistency in the application of the eligibility criteria and support the provision of high quality assessment services. They also provide accountability between assessment agencies and local authorities. Other recommendations in this report support these assessment agencies with the provision of information (handbook), training and some funding (recommendations r, s, t, v). These recommendations were not included in the consultation document.

18. That local authorities should make a financial contribution towards the cost of assessments and administration undertaken by assessment agencies.

While it is recommended that local authorities should make a contribution towards the costs of assessment services, it is not expected that it will necessarily cover the full cost. It is anticipated the costs would also be shared between the potential Scheme member as well as the voluntary agency. With regard to the latter, this is consistent with the founding tenet of the Scheme, which involves voluntary sector, local authority and central government co-operation. Further, it is not expected that the assessment process should be complex and require professional expertise, and hence create additional associated costs.

This proposed improvement was supported by 58% of all submissions and 63% of assessment agency submissions. However eight of the 14 local authorities that expressed a view on this proposal, were not supportive.

19. That appropriate training is provided to assessors to assist in the consistent application of the eligibility criteria.

This recommendation is in conjunction with the provision of a handbook (recommendation t). It is anticipated that training seminars may need to be repeated from time-to-time as necessary, to meet the needs of new assessors in a region.

This proposed improvement was supported by 75% of all submissions, and 77% of assessment agency submissions.

20. That a handbook, including best practice guidelines, be developed and published by Land Transport NZ in conjunction with local authorities, to help assessors in consistently applying the eligibility criteria.

It is recognised that volunteers, who may have a varying range of experience and knowledge about the eligibility criteria for the Scheme, frequently undertake the assessments. Currently there is scope to interpret the criteria and apply them in different ways, and this potential continues to exist (although to a lesser extent) under the revised criteria. A handbook will provide more detailed information to assist consistent interpretation of the criteria, and provide examples, particularly with regard to potential 'grey' areas. This handbook could be updated from time-to-time to reflect any future emerging areas of inconsistent interpretation.

It should also provide guidance about conducting a safe, high quality and confidential assessment. It is expected that for most applicants, the assessment process should be uncomplicated, relatively short and focused only on collecting the minimal information necessary for establishing eligibility. The guidelines would also help assessors identify if a more specialist assessment was required, and when it would be appropriate to seek expert advice.

This proposed improvement was supported by 87% of all submissions, and 91% of assessment agency submissions.

21. That the assessment process assists Total Mobility Scheme members estimate how many trips they would use (self assessed needs). This information will be provided to local authorities to assist them determine the appropriate number of allocated subsidised trips.

Scheme members will all vary with regard to the number of subsidised trips they need and can afford to use (given they pay 50% of the fare themselves). Accordingly, it is recommended that the number of trips allocated should be based on an applicant's own assessment of what is needed (whether occasional, weekly or daily trips) rather than the allocation of a fixed amount at fixed intervals. Guidance for the assessor and applicant to help applicants calculate how many subsidised trips they need and are likely to use over a given period, could be provided in the handbook (recommendation t). This information should assist local authorities allocate an appropriate level of subsidised trips to Scheme members (see recommendation n).

This recommendation was not included in the consultation document.

22. That potential members of the Total Mobility Scheme are not required to become financial members of an assessment agency in order to have an assessment for the Scheme, although they may be asked to pay an application fee. The appropriate amount of any such fee should be negotiated between Land Transport NZ, local authorities and assessment agencies.

The requirement by some assessment agencies for potential Scheme members to join and pay annual membership fees raises legal issues. Such a requirement may be inconsistent with the right to freedom of association under section 17 of the New Zealand Bill of Rights Act 1990.

The right to freedom of association encompasses the right not to associate with others. A person's decision to join or refrain from joining an organisation should be free from any form of compulsion, coercion, incentives or disincentives that remove the exercise of choice. Requiring potential Scheme members to join the assessment agency in order to gain entry to the Scheme effectively removes their exercise of choice as to whether to join the organisation.

The proposal that people who use the Scheme should not have to join an agency was supported 63% of all submissions, and 57% of assessment agency submissions.

23. That potential members of the Scheme have the option to be assessed by a voluntary disability sector agency in every region.

It seems important that potential Scheme members have access to at least one relatively low cost (or no cost) assessment agency in their region. Voluntary disability sector agencies play an important role in supporting the Scheme by providing low or no-cost assessment services ³⁹. It is recommended that this co-operation between the voluntary sector, local government and central government be supported.

This recommendation was not included in the consultation document.

4.5 Administration

4.5.1 Current policy context

Administration of the Scheme is primarily the responsibility of local authorities, but is sometimes delegated to voluntary assessment agencies. Both the way and extent to which responsibilities are allocated between the two parties varies considerably between regions. Most local authorities and agencies use administrative systems that are labour intensive relying on paper-based systems to allocate vouchers, collect information and monitor use. While some local authorities do have a computerised database, their capabilities differ and do not tend to generate data sets that are easily comparable.⁴⁰

4.5.2 Key issues

The lack of data collection, monitoring and evaluation of the Scheme is problematic. The variability in the current capabilities of local authorities to collect information, as well as the region specific way in which data is collected, makes it difficult to provide a national profile of the Scheme. Further, little information is collected about the travel patterns and needs of Scheme members, and the extent to which travel needs are met by the Scheme.

Scheme members can have difficulties redeeming vouchers when they travel to other regions. Each region allocates its own vouchers, and some accept vouchers from other regions, while others do not.⁴¹

Many people who are potentially eligible for the Scheme are not aware of it, as the Scheme is not promoted in most regions.⁴² As noted in an earlier section, this reflects a perception by local authorities that the number of eligible members may potentially be very high, posing a threat to the viability of the Scheme financially and administratively.

The following recommended improvements focus on improving administrative systems and Scheme promotion. Collectively these recommendations improve the adequacy, consistency, portability and sustainability. (see 7)

4.5.3 Recommended improvements

24. That Land Transport NZ encourages local authorities to establish systems for data collection, monitoring and evaluation.

The systematic collection of regional and nationally comparable data is an essential component of any successful Scheme. It will enable the effectiveness of the Scheme to be monitored and regularly evaluated.

This recommendation was not included in the consultation document.

25. That Land Transport NZ encourages local authorities to improve their administrative systems for the allocation and redemption of trip entitlement vouchers.

This recommendation was not included in the consultation document. However 88% of respondents supported the development of an administration system that could be used by all local authorities.

26. That local authorities implement appropriate methods to promote the Total Mobility Scheme. This should be phased in following the implementation of other improvements to the Scheme.

People who meet, or are likely to meet the eligibility criteria for the Scheme should be made aware of the Scheme and its potential benefits. Awareness can be increased by the provision of appropriate and accessible information to those most likely to benefit.

This proposed improvement was supported by 81% of all submissions. Nine of fourteen local authorities that responded to this proposal agreed with it. Most local authorities in favour of promoting the Scheme also expressed concerns that increased publicity could overwhelm councils and agencies with enquiries, assessments and increased demand for services. They all recommended promotion be targeted towards groups that are likely to be eligible.

4.6 Transport operators

4.6.1 Current policy context

Since its inception, the operation of the Scheme has depended on the availability of taxi services, and accordingly, has been limited to areas where these operate. To meet the needs of all Scheme members, some of these taxis require the capacity to carry wheelchairs. Some local authorities have contracts with the taxi operators participating in the Scheme, while others do not. ⁴³ The content of these contracts with taxi companies varies between regions, and may contain training requirements and/or include the provision of wheelchair accessible taxis in their fleet. There appears to be variability in the quality and standard of service provided by operators to Scheme members, although the Taxi Federation has produced a training video for its members to improve standards.

Wheelchair accessible taxi vehicles
Each local authority determines the level of financial support provided for the capital costs for the purchase and installation of wheelchair hoists and vans. This varies between full or partial support to cover the purchase and installation cost of a hoist. In 2003 the financial assistance rate (FAR) increased from 40% to 60% to encourage local authorities to replace ageing wheelchair hoists in taxi vans.

The Ministry of Education also contracts these vehicles for conveying children with special needs, to and from school. As a result, wheelchair accessible taxi services are often not available to Total Mobility Scheme members at these times. These contracts are important for the financial viability of wheelchair accessible taxis. It should be noted that the Ministry of Education does not provide any direct contribution to the capital costs for purchase and installation of hoists (however this may be incorporated in the fare structure).

4.6.2 Key issues

The key issues relate to inadequate contracting arrangements between local authorities and Scheme transport operators, and the seemingly insufficient numbers of wheelchair accessible transport services. With regard to the first, there is both an absence of any contracting arrangements in some regions, and variability between contracts in other regions. This situation contributes to the inconsistency in the quality and levels of service provided throughout the country.

The Taxi Federation has advised that wheelchair accessible taxis tend to be less profitable than other taxi vehicles due to high capital costs, and fare structures that do not fairly reflect their higher running costs. These higher running costs are associated with increased unpaid time travelling between fares, and for loading, unloading and providing special assistance. Currently two local authorities have implemented mechanisms to compensate operators for the higher operating costs of wheelchair accessible taxis. [The capital costs for the purchase and installation of wheelchair hoists is currently subsidised by local authorities (to a varying extent) and Land Transport NZ, and subject to a 60% FAR for replacement hoists and a 40% FAR for the installation of new hoists].

There is a requirement for wheelchair hoists to meet a specified standard at the time of installation, however there is no requirement for on-going safety checks. This creates potential risk for people using wheelchair hoists, and provides no mechanisms for gauging the extent to the wheelchair hoist vehicles are mechanically sound.

In some regions, it is likely that taxis are operating in areas where there is no Scheme, potentially providing the extension of the Scheme into these areas. It is recognised that these same areas may not be subject to a public transport component of the local authority rates, and may not provide other bus, train or ferry services. Nonetheless, extending the Scheme into these areas may meet current unmet need, and could be investigated by local authorities.

As already noted, the Scheme transport service is mostly provided by taxis, however this situation is not necessarily optimal. There is potential to allow or encourage other transport operators to participate in the Scheme. For instance transport services that are operated by community trusts, and other operators that solely operate wheelchair accessible vehicles. It is of course essential that Scheme transport operators meet legal licensing requirements and have appropriate contracts with local authorities.

The following recommended improvements focus on implementing arrangements to improve accountability between transport operators and local authorities, and improving the quality and quantity of wheelchair accessible taxis. They also encourage the participation of appropriate transport operators in the Scheme. Collectively these recommendations improve the adequacy, consistency and sustainability of the Scheme. (see Appendix 7)

4.6.3 Recommended improvements

aa) That Land Transport NZ develops guidelines for contracts between local authorities and Total Mobility Scheme transport operators to ensure high quality and adequate service levels, including the provision of wheelchair accessible taxis within the fleets.

Contracts should specify requirements relating to: interpersonal skills and appropriate training for drivers; appropriate safety procedures (e.g. securing people and aids etc); vehicle and hoist safety standards; fare structures; hours of operation; and availability to ensure an adequate service (especially with regard to wheelchair accessible vehicles).

This proposed improvement was supported by 95% of submissions.

bb) That local authorities enter into contracts with transport operators, aligned with the guidelines produced by Land Transport NZ.

Requirements for appropriate contracts with appropriate transport providers will have a significant role in ensuring an acceptable quality and standard of service. Appropriate contracts can also support an adequate wheelchair accessible transport service.

cc) That Land Transport NZ encourages adequate provision of wheelchair accessible taxis by providing a flat payment (in addition to the fare) to the transport operator for each trip taken by a Total Mobility Scheme member using a wheelchair hoist.

It is recommended that this flat payment be calculated to include both the higher operating costs of these vehicles, as well as the capital costs of purchasing and installing the wheelchair hoist. This approach is consistent with the way the Ministry of Education contracts for wheelchair hoist taxi services. [Currently the purchase and installation cost of wheelchair hoists is subsidised by local authorities and Land Transport NZ, and is subject to a 60% FAR for replacement hoists and 40% FAR for new hoists]. However this recommendation has not been properly modelled, and further work will be necessary to calculate an appropriate level of payment.

This recommendation has not been subject to consultation, and will not necessarily be welcomed by the Taxi Federation. It should be noted that the Taxi Federation is an advocate of increasing the FAR to 100% for the purchase and installation of wheelchair taxi hoists, in addition to a flat payment per trip to take account of increased operating costs.

This recommendation was not specifically included in the consultation document.

dd) That Land Transport NZ investigates the establishment of an appropriate regime to ensure that wheelchair hoists meet acceptable safety standards.

An associated issue includes the need for regular safety checks of wheelchair hoists as there is currently no appropriate testing regime. Without such a regime, it is difficult to assess the adequacy of the current fleet of wheelchair hoist equipped taxi vehicles, and even more obviously, to protect the safety of people using these hoists.

This recommendation was not specifically included in the consultation document.

ee) That local authorities are encouraged to investigate the possibility of contracting taxi services operating in areas that are not currently covered by the Total Mobility Scheme, to provide a Scheme service.

Currently there are some areas that operate taxi services, but do not operate a Total Mobility Scheme. Potentially the Scheme could be extended into these areas.

This recommendation was not included in the consultation document.

ff) That the possibility of other types of transport providers participating in the Total Mobility Scheme is investigated.

The proposal (contained in the consultation document) to improve and increase the fleet of wheelchair accessible taxi services was supported by 85% of consultation submissions. Issues for improvement included: ageing vehicle fleet and hoists, lack of safety checks, ongoing driver training, additional funding for loading and unloading and availability of vehicles at peak times.

Footnotes:

31. Data obtained from local authorities indicates the average number of trips taken per person per month on the Total Mobility Scheme ranges from a high of 5.9 trips to a low of 1.17 trips.
32. The Transfund NZ Total Mobility 2003 report (p56) noted that for those people who participated in its survey, 84% earned less than $20,000 per annum, and 38% earned $10,000 or less. The NZ Disability Survey Disability Counts (2001) found that the personal incomes of adults with disabilities are lower than those without disabilities (p17).
33. The Ministry of Transport plans to conduct this survey annually.
34. On the same basis, a guided self assessment method for determining the required amount of subsidised travel is one of the recommendations and is discussed further in the assessment section of this paper.
35. Currently (2004/5) it is providing members with 93% of their requested allocation.
36. These agencies include IHC, CCS, Royal NZ Foundation of the Blind, Age Concern and others.
37. At least three local authorities only use general practitioners to provide assessment services for the Scheme.
38. At least three local authorities have contracts with agencies.
39. Note that some agencies may require a membership and/or assessment fee from potential Scheme members.
40. At least three local authorities have databases, and one has smart card capability which provides for easier data collection.
41. At least two local authorities do not accept vouchers from other regions.
42. At least two local authorities undertake targeted promotion of the Scheme.
43. At least four local authorities do not have contracts with Scheme taxi operators.

<< Previous | Contents | Next >>

---

Download the full document:

• Total Mobility Review document (PDF v7.0, 161kb)