Appendix 4 - Total Mobility Scheme Review

The Total Mobility Scheme

Appendix 4 - Analysis of Submissions

(Executive Summary)

Analysis of Submissions

Transfund New Zealand, now known as Land Transport New Zealand (Land Transport NZ), started the Total Mobility Scheme Review (the Review) in 2002, as part of the Passenger Transport Social Services Review (phase one). In 2004, the Review was extended into a second phase with a broader Terms of Reference to:

• Investigate and identify options for addressing the key issues highlighted during phase one of the review of the Scheme;
• Consult with local authorities, relevant support agencies, people with disabilities, and transport operators about opportunities and options to improve the Scheme;
• Evaluate options against adequacy, consistency, portability, sustainability, and coverage criteria.

 
As part of its Review of the Total Mobility Scheme, the Ministry of Transport carried out a consultation process which sought submissions on six areas where possible improvements could be made to the Scheme. These six areas comprise of purpose, eligibility, entitlement, assessment services, administration and transport operators. 

SUMMARY OF FINDINGS

Scheme Purpose and Eligibility Criteria

Included in the consultation document that the Ministry of Transport released were possible options for improvement to the Scheme purpose statement and eligibility criteria. The two proposals received strong overall support from submitters; 88% and 84% respectively.

People who use the Scheme and disability organisations welcomed the proposals, particularly the prospect of greater consistency in determining eligibility. The proposed criteria's reference to the ability to complete each phase of a public transport journey, and to do so in safety and with dignity, was welcomed.

Eleven of the 14 local authorities that manage and operate the Scheme and made a submission supported the proposed purpose statement and nine supported the proposed eligibility criteria. In doing so, however, strong reservations were expressed regarding the cost implications of any widening of eligibility for the Scheme. It was felt that newly eligible groups could divert resources away from those with permanent disabilities, and place additional demands on ratepayer funds. One of the local authorities considered that the proposals should be the responsibility of health, social or welfare agencies funded from general taxes, rather than by ratepayers.

Responses were sought around eligibility of different groups, including people living in different situations and with different durations of impairments.

• Eligibility for people living outside areas served by bus, train or ferry services was favoured by 92% of all respondents. Some of the local authorities raised difficulties where these people did not pay urban transport rates that part funds the Scheme.
• Eligibility for people with short-tem impairments was supported by 85% of all submissions, although a minimum duration of a disability was raised as needing to be defined. Six of 14 local authorities that manage and operate the Scheme and made a submission were opposed, concerned at potential administrative difficulties and the diversion of resources from those permanently impaired and who are most in need of the Scheme.
• There was little dispute that impaired people living in residential care, both the elderly and younger people with impairments, should have access to the Scheme. Transport costs that are covered by the Ministry of Health payments for subsidised rest home residents should not, however, be absorbed by the Scheme.
• Access to the Scheme by children with impairments, although supported as an issue of principle, was not seen as a priority by users, disability organisations or transport operators. Local authorities that manage and operate the Scheme, and DHBs, strongly supported impaired children's entitlement to the Scheme for trips not covered by Ministry of Education funding. The treatment of children with impairments below the age at which they could be expected to travel alone, if not for their impairment, needs to be further addressed.
• Access to the Scheme by people whose impairment allows them to use buses, trains or ferries at some times but not at other times as a result of their impairment was supported by 86% of respondents. Eight of 14 local authorities that manage and operate the Scheme and made a submission supported eligibility for these people but five were opposed, concerns were raised based on the difficulty of monitoring and preferring to direct resources to those they saw as more in need of support.
• An assessors' handbook that would elaborate and interpret the Scheme's eligibility criteria was proposed in the consultation document. 87% of all respondents, including all local authorities and all DHBs supported the proposal, although requesting that it allow individual circumstances to be taken into account. Some assessment agencies were content with current arrangements and viewed assessment decisions as clear-cut. There were suggestions from the local authorities that the Ministry of Transport or Land Transport New Zealand should take an active role in promoting consistency through the handbook, training and co-ordination. 

Entitlement

The consultation document sought views on aspects of Scheme entitlements.

Standardising the fare subsidy at 50% was supported, for consistency and ease of use, by 89% of submissions. Eleven local authorities endorsed a nationally consistent subsidy rate, drawing a parallel with other transport funding, although two suggested that the rate might be other than 50%. One sought to retain flexibility in the subsidy rate to manage expenditure.
The setting of maximum subsidised fares using a nationally consistent method was supported by 79% of all respondents; many of those opposed asked that local factors be taken into account. All local authorities that manage and operate the Scheme and made a submission supported the use of maximum subsidised fares, with seven of 14 favouring the use of a consistent method. One felt that because the Scheme is not fully funded by central government, a nationally consistent regime is not appropriate. One DHB proposed the maximum fare subsidy be limited only by the user's ability to pay their 50% share.
The application of a minimum subsidised fare was opposed by 55% of respondents, including 13 of 14 local authorities that manage and operate the Scheme and made a submission, and all but one DHB. Although limiting administration for small fares, minimum subsidised fares were seen as discriminating against users who need to make only short trips. Transport operators were equally divided in their views.
The use of a nationally consistent method for deciding numbers of subsidised trips was supported by 51% of respondents. Regulating numbers of trips is used by several Schemes to manage demand and budgets, with allocations in many regions subject to consideration of individuals' needs.
Restrictions on the purpose of subsidised trips, other than those that should be covered by other schemes such as ACC, were rejected almost by all respondents.

Assessment Services

Views were sought on whether people seeking assessment of their eligibility for the Scheme should be required to pay for the assessment and/or to join a support organisation, and whether local authorities or government should make a contribution towards the cost of the assessment.

• The proposal that a contribution be made to assessment costs was supported by 58% of submissions, but many of those opposed appeared to misunderstand the question. Ten of 14 local authorities opposed contributions being made.
• Regular compulsory training for assessors was favoured by 75% of respondents overall, 77% of assessment organisations, and 12 of 14 local authorities that manage and operate the Scheme and made a submission. It was suggested that training needed to focus on the requirements of Scheme eligibility rather than the assessment of disabilities per se.
• A payment by applicants seeking assessments was opposed by 66% of all respondents, and 73% of users, as a barrier to entry. However, eight of 14 local authorities that manage and operate the Scheme and made a submission supported user payments, as did three of 12 DHBs.
• The suggestion that Scheme users be required to belong to assessment agencies was opposed by 63% of all respondents, although most could see benefits for the clients if they chose to join. Ten of 14 local authorities that manage and operate the Scheme and made a submission opposed compulsory membership assessment agencies in their areas. Several local authorities commented, however, that they could not afford the administration of the Scheme without volunteers. All DHBs opposed compulsion, one suggesting that the administration costs should be borne by Land Transport NZ. 

Administration

Views were sought on two administration proposals.

The development of an administration system that could be adopted by all local authorities was supported by 88% of submissions. Of the 14 local authorities that manage and operate the Scheme and made a submission, seven supported the proposed administration system, three were undecided and four were opposed. Three expressed concern about the possible cost and inflexibility of such a system. One said that it would not wish to replace its newly adopted system.
Publicity for the Scheme was supported by 81% of all respondents. Users, in particular, believed that many eligible people are not aware of the Scheme. Some suggested mass media advertising while most favoured continuing the current (albeit limited) methods such as pamphlets in doctors' rooms, etc. There was general concern that publicising the Scheme would result in the Schemes being overwhelmed by increased demands. Most local authorities indicated they would not support increased publicity unless additional government funding was forthcoming. 

Transport Operators

The development of guidelines for contracts between local authorities and transport operators was almost fully supported, provided appropriate recognition was given to the circumstances of small towns.
Improvements to wheelchair accessible taxi services were supported by 85% of respondents. Concerns included aging vehicles and hoists, the lack of a requirement for regular safety checks on hoists, the adequacy of tie-down and seatbelt systems, and the effects on other users of school transport commitments. Concern at the financial viability of many mobility taxi van services under current subsidy arrangements was voiced in submissions for local authorities, support organisations, users and transport operators. Many submitters sought greater funding for wheelchair services.

Priorities

Respondents were asked to identify the priorities for improvements to the Scheme.

• Clearly more respondents nominated "Eligibility" as the priority than nominated any other aspect of the Scheme.
• "Transport Operators" was the second most identified priority, nominated by about half the number that supported Eligibility.

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INTRODUCTION
BACKGROUND
PROJECT OVERVIEW
PROPOSED POLICY FRAMEWORK 
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