Proposed Policy Framework - Total Mobility Scheme Review

The Total Mobility Scheme

4. PROPOSED POLICY FRAMEWORK FOR THE TOTAL MOBILITY SCHEME

This section discusses each component separately, and the proposed recommendations relating to each component. It should be noted that although each recommendation will bring improvement to the Scheme, some recommendations are contingent on the implementation of others. Hence it is expected that improvements will be implemented progressively in stages. Even more fundamentally, the extent to which recommendations are accepted and implemented will be dependent on the extent to which government agrees to raise the Financial Assistance Rate (FAR) for the Scheme. There are financial costs associated with most recommendations, and these are outlined in section 5.

4.1 Scheme Purpose

4.1.1 Current policy context

The Scheme is founded on the central tenet that people with disabilities, unable to use buses, trains or ferries as a result of their disability, should be assisted with a subsidised alternative by local and central government. This tenet reflects the legislative requirement for local and central government to consider the needs of the transport disadvantaged⁶, and has since been further reinforced by the New Zealand Transport Strategy (2002). Consistent with this central tenet, provision of the Scheme is usually limited to urban areas that operate bus, train and/or ferry services, and taxi services. Further, the subsidised alternative provided by the Scheme has almost always been a taxi service, and therefore limited to areas that provide taxi services.

Transfund NZ described the current purpose statement in a report as follows:
"The goal of the Scheme is to increase the mobility of people with serious mobility constraints. The aims are to encourage participation in society and provide for personal independence, reduce pressure on caregivers, and allow people to continue living longer in their own homes if they prefer to do so."⁷

4.1.2 Key issues

Currently there is a lack of agreed understanding as to the purpose and parameters of the Scheme, and the extent to which local authorities accept the purpose statement (as described above) is unclear. Even more fundamentally, some local authorities may not necessarily consider this is their core business, but rather a social service that is the more proper domain of central government. The establishment of an agreed Scheme purpose and boundaries, and clarification of management and funding responsibilities underpin the proposed policy framework for the Scheme.

An additional issue is the description of the target group for the Scheme. The current purpose statement (as above) describes the target group as 'people with serious mobility constraints'. The current eligibility criteria describe the target group as 'people with disabilities'. The former description is very wide and generalised, and the latter is inconsistent with the New Zealand Disability Strategy 2001 (NZDS). The NZDS states "Disability is not something individuals have. What individuals have are impairments. They may be physical, sensory, neurological, psychiatric, intellectual or other impairments" (p1).

The following recommended improvements establish a national purpose statement for the Scheme, including clarification of the central rationale and Scheme parameters. Collectively these recommendations improve the adequacy, consistency, sustainability and coverage of the Scheme (as shown on Appendix 7.)

4.1.3 Recommended improvements

1. That the following Total Mobility Scheme purpose statement is nationally agreed and applied:
   "The Total Mobility Scheme is to assist eligible people with impairments to access appropriate transport to enhance their community participation. This assistance is provided in the form of subsidised door-to-door transport services wherever Scheme transport providers operate."

This statement is the same as the one proposed in the consultation document, except for the omission of the additional objective to "reduce social exclusion". If this objective was included as part of the Scheme purpose, it may require a more complex assessment regime and bear fewer of the characteristics of a public transport service (and be less consistent with the central tenet of the Scheme) and be more akin to a social service.

The proposed purpose statement also defines the target group for the Scheme as people with impairments (rather than disabilities) who are prevented by their impairment from using buses, trains or ferries. The World Health Organisation (WHO) defines impairment as "any loss or abnormality of psychological, physiological, or anatomical structure or function." It also defines disability as "any restriction or lack (resulting from an impairment) of ability to perform an activity in the manner or within the range considered normal for a human being."⁸ Both terms have applicability for establishing eligibility for the Scheme, in that to be eligible, a person must have an impairment, that prevents them from being able to use buses, trains, or ferries (the latter part of the sentence referring to the disability resulting from the impairment).

The proposed purpose statement in the consultation document was supported by 88% of the submissions received.

1. That the founding central tenet of the Total Mobility Scheme, and the role of local authorities in providing the Scheme, is supported and strengthened.

The provision of a subsidised transport service to eligible people with impairments is consistent with local government responsibilities to the transport disadvantaged, and part of core business⁹. The Scheme is primarily a transport service, and is no more a social, health or disability service than any other type of transport service. Any person would be at risk of social isolation and adverse health outcomes, if they did not have adequate access to appropriate transport. The Scheme provides its members with access to transport to participate in their communities in whatever way they choose. The destination they choose to travel to is their choice, and consistent with the way other people are able to use buses, trains or ferries.

However it is not intended that the Scheme should be a substitute for transport services that should more appropriately rest (or be shared) with other government agencies such as health, education or Accident Compensation Corporation (ACC). It seems appropriate that people who have a particularly high and frequent need to access specialist medical or other such services, should be eligible for additional transport assistance from these same services.¹⁰ Local authorities have expressed concern that unfair cost shifting does occur. One way of conceptualising the respective responsibilities of agencies in providing subsidised transport is depicted in the diagram below. The diagram situates the Scheme as a component of public transport, and an appropriate local authority responsibility. The Scheme clearly has overlapping benefits to health and disability services (as well as education and others) as many people use the Scheme to access these services. However if the Scheme becomes monopolised by a particular trip purpose (or service area), such as getting to hospital, the Scheme purpose is potentially compromised (that being to assist community participation). 

Figure One: Situating the Total Mobility Scheme: a possible view

Figure One: Situating the Total Mobility Scheme: a possible view. 

Overall the cumulative impact of such a trend could, arguably, move the Scheme away from being an appropriate local authority responsibility and towards that of another service. It could also threaten the current funding source for the Scheme, that being local authorities and the National Land Transport Fund. Issues regarding the appropriate scope (and funding source) of the Scheme, are likely to continue being contentious into the future, especially if local authorities perceive inappropriate cost shifting by other agencies. Improved data collection about the travel behaviour and travel needs of people who use the Scheme, will assist in monitoring trends in this area. This should also be the subject of future inter-sectoral work between government agencies and local authorities.

1. That the Total Mobility Scheme parameters are clearly defined.

This will clarify the limits of service provision within a finite budget. The latter will be discussed in a subsequent section on entitlement (see Section 4.3). With regard to the former, the following elements clarify the limits of service provision and are already consistent with common practice:

• Provision of subsidised transport assistance to people with impairments;
• Transport alternative to be provided by way of a subsidised door-to-door transport service;
• Limited amount of subsidised transport assistance available;
• Limited to areas where Total Mobility Scheme transport providers operate;
• Limited to local trips;
• Subject to nationally consistent eligibility criteria;
• Subject to some regional variation of entitlements to reflect local differences.

These elements will be preserved and strengthened as part of the proposed overall policy framework. Further elaboration on each of these elements will be discussed in the appropriate sections of this paper as indicated above.

4.2 Eligibility

4.2.1 Current policy context

There are nationally consistent eligibility criteria defining the target group that are applied by local authorities and assessment agencies:

"The Scheme is available to people who, because of physical, sensory, intellectual or psychological disability are unable to: proceed to the nearest bus stop/train station; board, ride securely and alight; and proceed from the destination stop to the trip end without assistance".

4.2.2 Key issues

The current eligibility criteria are reasonably robust and consistent with the Scheme rationale. However the current eligibility criteria are interpreted and applied differently between regions, and sometimes within regions by different assessment agencies. Further, particular groups of people might be accepted on the Scheme in some regions, but may be excluded in others. These four groups are:

• people who are able to use buses, trains or ferries some of the time, but not all of the time, due to the fluctuating nature of their impairment,
• people with short term impairments;
• children with impairments;
• people with impairments who live in residential care.

This variability in determining eligibility is inequitable, and reflects the lack of clarity about the purpose of the Scheme and the appropriate target groups. It also reflects the concern of local authorities to manage expenditure by limiting the number of people accepted on to the Scheme. Underlying all these issues appears to be a perception by local authorities that the number of eligible members may potentially be much higher, posing a threat to the viability of the Scheme financially and administratively.

This concern is validated in estimates provided by Statistics NZ. While approximately 43,000¹¹ people are registered members of the Scheme, it is estimated that 78,300 people could be eligible.¹² The number could be even higher if children or people who live in residential care are also included.¹³ Other information suggests that up to 5,400 children¹⁴ and 20,000 people in residential care¹⁵ may potentially also meet current eligibility criteria. However relatively small numbers of current Scheme members are children or live in residential care.¹⁶ It should also be noted that most Scheme members appear more likely to be amongst the older age groups with at least half (and probably many more) aged over 75 years.¹⁷ This trend will be further magnified in the future by demographic growth in older age groups.¹⁸

It is unclear why eligible people do not join the Scheme. For some it will be an active choice, while for others it will be the result of specific barriers. This group is likely to include those that:

• live in areas that do not operate a Scheme (barrier);
• do not know about the Scheme (barrier);
• have (or would) apply to be members, but are declined ¹⁹ (barrier);
• are not able to afford to pay 50% of the taxi fare (barrier);
• travel with others, or have their own private vehicles (choice);
• pay for their own travel costs (choice);
• do not travel.

Another significant issue, (included in the list above) is the ineligibility of people with impairments, who live in areas that do not have bus, train or ferry services. This effectively prevents otherwise eligible people from using the Scheme, when they are travelling within areas that do operate this service. For instance, when they are on holiday or conducting business outside their area of residence. Extending coverage to this group could increase the number of eligible Scheme members by an estimated 29,600.²⁰ It is unlikely however that this group will be frequent members of the Scheme, as their use will be limited to areas where the Scheme is available.

This group also includes those who may live on the outside fringes of urban areas that do provide bus, train or ferry services (including a Total Mobility Scheme). However this group is currently excluded because their area is not subject to a passenger transport component in their local authority rates.²¹ For this latter group, it has been an issue of contention that they are not eligible to use the Scheme (because public transport is not a component of their rates) even though taxis operate in their area.

The following recommended improvements focus on improving the eligibility criteria and supporting its consistent application across the country. These may address two of the potential barriers identified in this discussion, and are also likely to increase the number of registered Scheme members. Collectively these recommendations improve the consistency, coverage and portability of the Scheme (see Appendix 7.)

4.2.3 Recommended improvements

These proposed criteria are similar to the current criteria, although more clearly outline the necessary elements of an 'accessible journey', to assist determine eligibility. This is consistent with the approach outlined by the Human Rights Commission, which describes the accessible journey as follows:

"...this means that for a person to get from their home to a destination and then home again requires a number of linked steps. All these steps are of equal importance. If one link is broken or inadequate, the whole journey becomes impractical.²²

This proposed improvement was supported by nearly 90% of submissions received.

1. That people with impairments who meet the criteria for the Total Mobility Scheme, and are able to use bus, train or ferry services some of the time, but not all of the time, should be eligible for the Scheme.

It is not known how many people are in this category, although some local authorities allow this group to be members of the Scheme, and others do not. Examples of people in this category include people with impairments that may fluctuate and become more acute for periods of time (such as epilepsy or arthritis), hence their need to use the Scheme at these times. It may also include people with impairments (such as alzheimer's) that only allow them to travel, using buses, trains or ferries on very familiar routes, or people with visual impairments that only allow them to travel during day light hours.

This proposed improvement was supported by 86% of submissions.

1. That people who meet the criteria for the Total Mobility Scheme and have an impairment that has lasted or is expected to last for six months or more should be eligible for the Scheme.²³

Currently some people who have impairments that are defined as short-term by local authorities are accepted as members of the Scheme. In other areas, they may not be accepted.²⁴ However local authorities (and assessment agencies) define 'short-term' in different ways. In at least one region short-term is defined as a disability with duration of not less than one year, while in others it may be defined as a much shorter period. Data collected from local authorities suggested that the number of Scheme members who were classified as short-term were approximately 500 nationally.

Rather than defining 'short-term impairment', this recommendation proposes adding a concept of time to the proposed eligibility criteria. Consistent with definition used by the Ministry of Health²⁵, Statistics NZ added a concept of time to the WHO definition of disability for the purposes of the NZ Disability Survey. That is, that the disability must have lasted or be expected to last for six months or more²⁶. It is recommended that this same time duration requirement be incorporated in the eligibility criteria for the Scheme to provide consistency with their interpretation."

In addition, it should also be noted that accepting people with impairments of an expected duration of less than six months on to the Scheme, may exacerbate financial pressures on the Scheme, and potentially risk reduced entitlements for people with longer term or permanent impairments.

This proposed improvement was supported by 85% of submissions (however the term 'short-term' was never defined). Some local authorities expressed concern about the additional costs of including people with short-term impairments.

1. That children with impairments who meet the criteria for the Total Mobility Scheme should be eligible for the Scheme.    

Children are accepted as members of the Scheme in most, but not all regions, and number fewer than 250.²⁷ It is recommended that the Scheme should be available to children to support their independent participation in the community, in ways that are similar to other children in their peer group who do not have impairments. This could include trips to visit friends, or to see a movie.

It is not intended that the Scheme should be a substitute for transport services that are the responsibility of other government agencies, such as the Ministry of Education which is responsible for all school related travel. To provide an indication of the potential numbers of children who could use the Scheme, currently the Ministry of Education provides special transport assistance to 5,400 children who have impairments.²⁸

This proposed improvement was supported by 75% of submissions.

1. That people with impairments who meet the criteria for the Total Mobility Scheme and live in residential care should be eligible for the Scheme.

Most local authorities seem to accept people in living in residential care on the Scheme, although numbers are likely to be small.²⁹ However it appears that people living in rest homes have not always been accepted on the Scheme due to the perception that the travel needs of this group should be, or are being, met by rest home providers. However the Ministry of Health advises that rest home providers only have responsibility to meet the cost of transport for stipulated health services.

It is expected that the Scheme should be available to people who live in rest homes to support their independent participation in the community. This may be to visit friends or families, or go shopping. It is not intended that the Scheme should be a substitute for transport services that are the responsibility of the rest home provider, or be used by the rest home to provide transport for organised activities.

This proposed improvement was supported by 85% of submissions.

1. That people with impairments who meet the criteria for the Total Mobility Scheme, and who live in areas that do not have bus, train or ferry services should be eligible for the Scheme, enabling them to use the Scheme wherever it operates.

This group encompasses people who live in areas that do not operate bus, train, or ferry services, taxi services or a Total Mobility Scheme. Including this group in the Scheme, will allow them to use the Scheme wherever it operates (even if it does not operate in their local area).³⁰ For those people who live on the outside fringes of areas that do provide the Scheme, it is expected that where possible, this group should have access to the Scheme (even though they are not subject to the public transport rating component). As this issue is region specific, it is expected that the inclusion of this group should be a subject for negotiation between the relevant local authority and Land Transport NZ.

This proposed improvement was supported by 92% of submissions, however local authorities expressed concern about the additional costs of including this group of people.


Footnotes:

6. Land Transport Management Act 2003, Part 2, section 35.
7. Transfund NZ Total Mobility 2003 p1.
8. Cited from Statistics New Zealand Disability Counts (2002) p128. These definitions were applied by Statistics NZ for the NZ Disability Survey.
9. This is consistent with the Land Transport Management Act 2003, Part 2, section 35 and with the NZ Transport Strategy (2002).
10. The intention is not to limit the extent to which people can use the Scheme for health services, but to encourage other agencies to consider, and where appropriate, assist meeting the transport needs of their clients.
11. See Table B, Appendix 1
12. See Summary of Statistics New Zealand Report (Appendix 8).
13. This estimate does not include children and people who live in rest homes as the Household Disability Survey 2001 did not collect this data. See Summary of Statistics New Zealand Report (Appendix 8).
14. Ministry of Education advises it currently assists approximately 5,400 children with school travel as a result of their impairments (July 2005).
15. The Ministry of Health estimates that approximately 12,000 people aged over 65 are living in rest homes, and that 8,000 people aged under 65 years are living in residential care.
16. Description of Total Mobility Schemes (Appendix 6).
17. Estimated from data provided from local authorities, and information contained in the Transfund Total Mobility 2003 pp53-54.
18. Refer Summary of Statistics New Zealand Report (Appendix 8)
19. This includes those people who may have been declined, due to narrow interpretation of the eligibility criteria by one local authority or assessment agency, but may have been accepted as eligible by another.
20. Summary of Statistics New Zealand Report (Appendix 8)
21. At least three local authorities only provide the Scheme in specific areas that are rated for public transport services.
22. Human Rights Commission Inquiry into Accessible Public Land Transport Consultation Report April 2004 p23.
23. Excluding people with terminal illnesses.
24. At least four local authorities do not accept people with short-term impairments on their Schemes. However their respective definitions of short-term vary.
25. The Ministry Health advised that it introduced the six months threshold in their definition of disability in 1994. Source: Ministry of Health.
26. Statistics New Zealand Disability Counts (2002) p128
27. At least two local authorities do not accept children on the Scheme. For the13 local authorities that do accept children on the Scheme, only seven could provide actual numbers, giving an estimated total of 250 children. However age definition for a 'child' varied between them.
28. Figure provided by the Ministry of Education
29. At least one local authority does not accept people living in rest homes on the Scheme. For the 11 local authorities that do accept people living in residential care, only five could provide actual numbers, giving an estimated total of approximately 3000 people.
30. These people will be able to use the Scheme when they travel to areas that do operate the Scheme.

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