Are there any additional criteria that could be used to establish automatic service eligibility?
Are there any additional measures we could take to make the application process easier?
It is well documented that awareness and takeup of schemes such as Taxicard and Dial-A-Ride is lower among those from an ethnic minority.
The previous D-A-R form included one the front inside page: ‘If English is not your first language and you would like assistance using a telephone-based translator, please contact London Dial-A-Ride Customer Liaison Unit…’
In order to ensure that D-A-R reaches all segments of London’s population, it’s important that the new form ensures makes this same offer at the front of the form.
The current form only has a tickbox on the 9th page, with the phrase ‘English is not my first language and I need an interpreter (please specify language)’
But it’s highly unlikely that somebody who speaks does not have English as a first language, or indeed their friend or relative, will get far enough to find this box and fill it in. TfL must ensure an offer of a translator is made on the first page, translated into the most common languages as well.
Are there any ways the form could be made easier to complete?
TfA support the option of an online form, as internet usage becomes more common. We also support the need for an Easyread version of the form or information about D-A-R: a significant proportion of present D-A-R users have some form of learning disability.
Please provide any further comments below.
1. TfA have grave concerns about using independent mobility assessors, given that they have a poor reputation among disabled people for making fair judgements
The fact that TfL state that 13-16% of future applicants will be declined by DAR adds to our concern that assessment will be target-driven, rather than responding to the real needs of disabled and older people. It seems likely that, as has happened in other contracts for assessment of disabled people, the companies place assessors under pressure to meet client’s targets.
Futhermore, many disabled people say that independent mobility assessors do not have an adequate knowledge of rarer presentations or forms of impairment.
TfL state that they would apply the same principles to DAR assessments as they do for the Taxicard assessments. TfA have dealt with around twenty complaints in the last year against these Taxicard assessments, and succeeded in getting several decisions overturned. Cases include:
· A gentleman with MS who was refused a Taxicard
· A gentleman with severe autism
· A lady who had an angina attack in the middle of her assessment – and was deemed ineligible.
These represent the tip of the iceberg when it comes to unjust decisions by assessors, as the vast majority of people who are unfairly assessed may not know of our complaints service or do not complain.
2. There is a clear agenda here to cut the numbers of people who use D-A-R
The proposal suggests that ‘all current and future users of DAR will benefit as these changes will allow DAR’s resources to be focussed on those who really need them, and refers to ‘our limited dial a ride services’. The form is designed to discourage applicants and to make criteria for membership more stringent. This strongly suggests that people by TfL’s budget limitations, rather than levels of reduced mobility among disabled and older Londoners.
Turning away people who otherwise have no means for getting out and about, and condemning them to being housebound or dependent on others, is not a worthwhile price to pay for better ‘focussing’ the resources of D-A-R.
3. The right to appeal decisions, as in the previous D-A-R assessment process, must remain.
Details of how to should be clearly laid out on the first page, as is the case with the current D-A-R form. It is unrealistic to expect assessors to be infallible, and there must be recourse for those unfairly turned away.
Members of the Commons work and pensions committee were told earlier this year that as many as 80 per cent of people who have been represented by benefits experts in their appeals against being found “fit for work” have had that decision overturned. There must be a system in place for reviewing decisions on D-A-R membership, so that if there is such systematic misjudgement as there appears to be in benefits assessment, it can be picked up on.
4. TfA supports the principle of offering everyone who is refused the Travel Mentoring Scheme
This scheme works well for people with particular impairments (e.g. those with learning disabilities) but it only works to increase confidence while travelling on London transport.
A large proportion of people apply to D-A-R because they find it too difficult to get to a bus stop or station in the first place; or because of the limitations of the stops or stations they can reach (e.g. bus stops which cannot be used by wheelchair users; stations with no stepfree access).
We would welcome TfL publicising the scheme to those who are successful in their application as well, because some of those who are automatically eligible (e.g. some wheelchair users who can reach stepfree stations; some visually impaired and blind people) can use some mainstream transport with training.
5. TfA are concerned that the change in wording from ‘people with mobility problems’ on the previous DAR form to ‘disabled people’ will discourage applicants.
Very very many older people with mobility problems DO NOT identify as disabled; or associate disability with visible conditions such as being a wheelchair user.
Similarly, people who are covered by the DDA definition of disability because they have cancer, multiple sclerosis, HIV or a progressive conditions such as cystic fibrosis, Alzheimers disease, Huntingtons chorea, muscular dystrophy or motor neuron disease, do not always consider themselves disabled, although their mobility and ability to use mainstream public transport may be severely impaired. Some of these people will be entitled to DAR as a result of automatic criteria, but not all.
TfA feel it is vital that people whose ability to use public transport is affected as a result of one of these conditions are covered.
Many of those who do do not identify as disabled find it impossible or very difficult to use public transport. Dial a Ride should remain a service for disabled AND older people – that includes older people with reduced mobility. This is not semantics. Many older people we work with have a reluctance to claim services they are entitled to, feeling they ‘don’t want to be a burden’, and so the preamble to the form is important to encourage people who would benefit greatly from the service but would be put off applying by the proposed form.
The form should either say it is for people with mobility problems, or include a sentence clarifying the word ‘disabled’ in a broad context, recognising that conditions such as continence issues, communication impairments, a heart condition, or epilepsy can make it impossible or difficult to use mainstream public transport.
This change of wording seems clearly designed to reduce the number of DAR members, at the cost of leaving many older people isolated at home with no form of transport.
The Mayor’s Transport Strategy rightly emphasised the ‘Whole journey model’, which includes any difficulty getting to the public transport in the first place!
This must be reflected in offering door-to-door transport to people who, while they may be able to use a bus or train once on it, cannot reach the stop or station.
6. The proposed form uses the discredited medical model of disability, despite the fact that TfL, as part of the GLA group, has ‘fully adopted’ the social model of disability.
Section 2b has replaced the question on the previous form, ‘describe what makes it difficult for you to use public transport, please include as many factors as you feel are relevant’, by please explain how your disability affects your ability to use public transport’.
The section is now entitled ‘Your Health and Disability’ rather than ‘non-automatic eligibility’, and eschews to invite documentation on benefit entitlement, inviting only medical documentation.
This sites the problems in the person’s disability – the medical model.
We also strongly believe that the principle of the ‘Social model of disability’ needs to be applied to all of the Mayor’s work on transport. Viewing the inaccessibility of transport services as the factor the ‘disables’ people rather than an individual’s impairments is vital if we are to make progress.
Many DAR users and potential users find transport inaccessible because a stop or station is too far to get to, or because there is nowhere to sit at a bus stop, or because their nearest station has lots of steps. The social model means that there will be a greater need for DAR in some areas, where the available mainstream transport options are highly inaccessible. This is not reflected in the proposed form.
Furthermore, there are only two lines for the response, a reduction from the previous form, and it does not even invite continuation on a further sheet!
This is insufficient, as this is the most important question in establishing one’s eligibility.
7. TfA recommends changing the questions on whether you use public transport services.
The form asks whether you use low floor buses, trains or underground – yes or no.
A better question is how often.
People with reduced mobility may use tube twice a year when a family member or friend is available to drop them at station – so tick yes – but can hardly ever use it because they can’t get there without a lift.
Or perhaps they can use the services with a carer or friend, but not by themselves.
Many people have variable conditions where they have ‘good days and bad days’, and can use these services on good days.
All of these people would tick yes – and presumably be disadvantaged in their application as a result.
The form needs to reflect the fact that people may have a strong case to become a member, as they need a door to door service for day-to-day activities and special events, but may be able to use public transport under specific circumstances. People should not be penalised for being confident enough to use mainstream public transport when they are feeling up to it, or when external circumstances allow, even when they can’t rely on being able to do this regularly.
8. TfA have major criticisms of the way in which this consultation is carried out.
It’s scandalous that the notes accompanying the consultation state “We expect these changes to the DAR application process to start in April 2011’.
The consultation ends in April 2011, leaving DAR with no time to make changes as a result of consultation.
This exposes the consultation as a purely cosmetic exercise.
The consultation ran only for four weeks, and TfA was not sent the consultation document until 29th March, leaving only 2 weeks to respond.
I understand from a letter to the chair of London Assembly’s Transport Committee that that TfL has extended this deadline, but TfL has not informed TfA of this, nor any other disabled groups, to the best of our knowledge.
Furthermore, the online consultation still has the deadline listed as 15th April.
In addition, the scope of the consultation is very limited, provides no information nor invites feedback on criteria which will be used to assess the forms and phone calls from those who are not automatically eligible.
9. All boroughs should automatically invite those applying for Taxicard to apply for DAR as well through a box on the same form.
In practice, many people apply for both services at the same time, and as all Taxicard members are automatically eligible for DAR, this would be an easy and cheap improvement.
10. The £400,000 cost of the contract TfL is offering to carry out assessments would be far better spent in improving door-to-door transport.
The London Assembly Transport Committee review of door-to-door transport revealed that Dial-a-Ride remains significantly below target in its performance. It provides fewer journeys than it did in 2001/02, long waiting times are common and users often make repeated attempts to get through to book a ride.
TfA would like to see TfL investing in improving door to door services, rather than reducing the number of disabled and older people who can use it.
TfA are gravely concerned that disabled people who cannot use easily use buses and trains, but are refused Taxicard, may be now be turned down for DAR and will have no way at all of getting around except to rely on others. This will increase ill health and isolation in London.