Equality Impact Assessment - Results
| Title of Policy | Changes to passporting arrangements for the National Concessionary Travel Scheme. |
|---|---|
| Summary of aims and desired outcomes of Policy | Scottish Government is seeking to ensure continued eligibility to the National Concessionary Travel Scheme (NCTS) for those in receipt of disability benefits who are currently eligible for the Scheme as a passported benefit by adding receipt of Personal Independence Payments to the eligibility criteria for the Scheme |
| Directorate: Division: team | Bus and Local Transport Policy, Transport Policy Directorate |
Executive summary
Scotland-Wide Free Bus Travel for Older and Disabled People was introduced in April 2006. It permits free bus travel within Scotland on any registered bus service to anyone who lives in Scotland, and is aged 60 and over, or meets certain disabled criteria, and has applied for and received a National Entitlement Card (NEC).
The eligibility criteria for disabled people include receipt of higher or middle rate care component or higher rate mobility component of Disability Living Allowance (DLA). In terms of the UK Government's Welfare Reform Act 2012, DLA for people between the ages of 16-64 will be gradually replaced with Personal Independence Payments (PIP) from April 2013.
Scottish Government is seeking to ensure continued eligibility to the National Concessionary Travel Scheme (NCTS) for those in receipt of disability benefits who are currently eligible for the Scheme as a passported benefit by adding receipt of PIP to the eligibility criteria for the Scheme.
We seek to maintain equivalence insofar as is possible with current DLA passporting arrangements by enabling all people deemed eligible for PIP as described in the Social Security (Personal Independence Payment) Regulations 2013 to become eligible for NCTS as a passported benefit.
All those eligible for PIP at standard and enhanced rate will be able to passport to a concessionary travel card. In addition all those who receive the daily living component of PIP (at either standard or enhanced rate) will be eligible for a Companion Card, allowing a companion to travel with them for free.
Transitional arrangements have also been included to allow those who have been in receipt of DLA, but following reassessment by DWP do not qualify for PIP, to retain their concessionary travel cards until the date of expiry.
Background
There are currently 189,000 people of all ages who hold Concessionary Travel cards on grounds of disability. The changes will affect all those aged between 16-64 who currently passport to concessionary travel through DLA and will be reassessed following the introduction of PIP.
The Department of Work and Pensions were unable to confirm how many or what groups of people might be affected by the changes. However, they indicate that they expect over 20% of all DLA claimants to lose entitlement once reassessed for PIP.
In light of this, we are putting in place eligibility criteria which will enable PIP recipients to passport to NCTS in much the same way as eligible recipients do at present. These criteria have been set at a level seeking to minimise the likelihood of anyone currently eligible for passporting to NCTS via DLA losing their entitlement once PIP has been introduced.
The Scope of the EQIA
The policy will affect those disabled people who currently passport to NCTS via entitlement to DLA. This will be the focus of this EQIA.
There may be an impact in terms of age as those people of working age will be treated differently from under 16s and over 65s when PIP replaces DLA.
There is no impact, adverse or otherwise, in terms of sex, gender reassignment, sexual orientation, race, religion or belief.
Key Findings
PIP will only be payable to people between the ages of 16-64 and there are currently over half of DLA recipients falling within this age group. People ages 65 and over and under 16 currently receiving DLA will continue to do so. Accordingly, people of working age will be assessed for disability benefit (and therefore eligibility for concessionary travel) differently than other age groups.
Because it is likely that there will be fewer PIP recipients than there were DLA recipients, some people previously eligible for NCTS via DLA may no longer be eligible for passporting if they lose entitlement to PIP.
The amendment to the Concessionary Travel Regulations will impact positively on disabled individuals of working age (both men and women) who receive PIP awards as the eligibility criteria for the scheme have been extended to allow them to passport to Concessionary Travel in the same way that those under 16 and those over 64 will continue to passport from DLA.
If the Regulations had not been amended to introduce the passport, many disabled individuals would not be able to passport and would be required to apply for a Concessionary Travel card through the other eligibility criteria.
The eligibility criteria for passporting from PIP mean that, while there may be reasonable numerical equivalence, we cannot guarantee that the same individuals will remain eligible. It remains a possibility that some cardholders currently eligible through DLA may not meet the PIP criteria and will therefore not be able to passport to NCTS. Conversely, others not previously eligible for NCTS may potentially gain access to the Scheme or to a companion card that they did not previously get if they are deemed eligible for PIP.
Additionally, eligibility for free bus travel is used by a number of Local Authorities to give access to local concessions. Losing access to the national scheme will lead to additional loss of access to these schemes, or require Local Authorities to introduce new assessment criteria.
The above findings directly informed the setting of the PIP eligibility criteria for NCTS at the level agreed, i.e. all PIP recipients will become eligible for passporting to the Scheme.
Recommendations and Conclusion
The policy change is a direct result of part of the UK Government's welfare reform provisions, the move from DLA to PIP. In formulating the policy we sought to mitigate the impact of these provisions on NCTS by ensuring that disabled persons of working age who receive PIP will not be adversely affected in terms of passporting to the Concessionary Travel Scheme.
To raise awareness, we have requested that DWP include concessionary travel in the list of passported benefits that will appear in the award letters that successful PIP claimants will receive and also in the letter informing people that they will not be awarded PIP, this latter because they may still be entitled to claim a concessionary travel card by virtue of the other eligibility criteria for disabled people. DWP have indicated that concessionary travel will be included in these letters from April 2014, though not earlier due to IT constraints.
Once Personal Independence Payments come into force in Scotland we will seek feedback from advocacy and stakeholder groups on the effects of the new passporting arrangements in order to determine if they are working correctly. We will also monitor the impact of the welfare reform changes on uptake of NCTS and seek to identify any groups who may have lost out as a result.
We are developing guidance to inform front line staff of the changes to the eligibility criteria. We will also seek general feedback, including if they have observed any particular groups being affected by the changes to the eligibility criteria.
Information will also be updated on our website and on the General Information booklet that supports NCTS and is issued to anyone looking to apply for a National Entitlement Card in order to access the Scheme.
We anticipate that any significant impacts of the welfare reform changes on NCTS will not arise until at least 2015, when the reassessment of existing DLA claimants are due to be rolled out. However, we will continue to monitor the impact of the changes on uptake of NCTS and seek to identify any groups who may have lost out as a result.
While developing our policy we have given due regard to the following needs in respect of the protected characteristics:
- to eliminate discrimination, harassment and victimisation;
- to advance equality of opportunity; and
- to foster good relations.