Process and administration

• Bus operators were largely positive about the operation of the Scheme, though noted views related to reimbursement
• Most cardholders found it easy to get information about the Scheme, but misunderstandings and conflicting advice suggest further awareness raising may be needed
• Most found the application, renewal and replacement processes easy
• Some called for the application and renewal processes for disabled cards to be revised for consistency, ease and to avoid duplication of effort
• Cardholders wanted a mix of application and renewal formats - online, telephone, postal, and in-person options

Integration with bus operators

All bus operators that provided feedback felt that the administration, processes and operational requirements related to the Scheme were fully embedded within their own day-to-day systems and worked well. In particular, operators noted that the ticket machines and links with back-office systems were either very well embedded, or were largely automatic. This helped ensure the day-to-day administration and operation of the Scheme was as seamless as possible:

Even where manual records of journeys were necessary for reimbursement, for example in remote areas with poor internet connection, the process was still considered to be well embedded and was viewed positively.

Survey respondents were asked if they had experienced any practical problems when using the free bus pass in the last 12 months. Table 24 shows that around three quarters of respondents (74%) had not experienced any problems, while 14% had experienced machines on the bus being broken.

Table 24 Have you experienced any of the following practical problems when using the free bus pass in the last 12 months? (survey respondents)

Note: multiple responses were possible at this question to percentages do not add to 100%.

Bus operators felt that the administration of reimbursement for concessionary journeys was well established and generally worked well.

One operator suggested that continuity of staff within both their organisation and at Transport Scotland was helpful to ensure a high level of knowledge and understanding of the Scheme and the required systems. All three commercial operators reported good relationships with Transport Scotland which were helpful and supportive in administering the Scheme and dealing with any issues that arose. One also suggested that it was helpful and more consistent having to deal with just one central authority rather than separate local authorities.

Meanwhile a community transport provider noted that support was provided by their local authority to administer and manage the Scheme, which helped with the smooth operation.

A few operators highlighted that, among other communications, a regular newsletter was published which helped to keep operators up to date. However, this received mixed reviews in terms of its usefulness. While most found this helpful, there was some concern that important information could be missed.

Larger operators also noted that they had a dedicated account manager and would have regular catch-ups. Some were also members of the Confederation of Passenger Transport (CPT) which helped to disseminate information about the Scheme and liaise with Transport Scotland on behalf of the industry in relation to more strategic and policy level issues. One operator did feel, however, that there was scope for more collaborative working and greater engagement between Transport Scotland and operators.

Impacts on bus operators

Most commercial operators indicated that the Scheme had not had any significant impact on the routes or timetables provided, the markets that they targeted, or on patronage patterns, (at least not more recently - they found it difficult to consider the full 19 year operational period). Rather, they tried to offer services suitable to all passengers, developed networks based on changing communities and usage patterns, and updated services based on the total demographics and needs of all passengers. Similarly, community transport providers did not report changes in services as a direct result of the Scheme, but noted changes in service provision due to the Covid pandemic and changing local demographics (such as an aging population) instead. Importantly, two community transport providers noted that it was increasingly difficult to operate suitable services in remote rural areas which sought to serve older and increasingly frail populations using the permit model required for eligibility in the Scheme:

Amongst operators there was typically no ongoing impacts of the operation of the Scheme, and any training required for new drivers was largely embedded in standard practices. Operators discussed providing training, awareness raising, and working with third sector organisations related to disabilities, carrying older passengers, and safeguarding. They also noted that they had been updating their fleets to improve accessibility. However, any changes implemented in this respect were said to be linked more to equality legislation and industry guidelines. Only one operator identified ongoing training as a direct result of the Scheme. They provided annual driver refresher training which included consideration of the rules of each concessionary travel scheme and how to identify and tackle fraudulent use.

Commercial operators indicated that while they undertook engagement with service users to inform service provision and any changes, this tended to include the broad range of users, and did not specifically target older and disabled users. Community transport organisations did not identify any engagement activities with passengers, or specifically with older and disabled cardholders.

One commercial operator acknowledged that the Scheme had grown to become a much bigger part of their income and represented an important part of their commercial offering - but this was not necessarily positive:

Issues and challenges for bus operators

The main challenge raised by operators related to their views on the rate at which journeys made under the Scheme are reimbursed.

Bus operators are financially reimbursed for each individual journey made under the Scheme and the Young Persons’ Scheme. Scottish Ministers have an objective (but not a duty), set out in legislation, to ensure that bus operators are financially no better or no worse off as a result of their participation in the National Concessionary Travel Schemes. This principle underpins the methodology for calculating the rates, which also take into account latest industry data including operator costs and inflation. The rates are agreed annually following negotiation with Transport Scotland, the Confederation of Passenger Transport (CPT), and industry representatives. The methodology underpinning the annual calculation of the reimbursement rates was updated in 2024. This review considered the latest available evidence on industry costs, passenger demand and travel behaviours, and was agreed with CPT and industry representatives.

The fares that operators would have received from NEC passengers are calculated using the latest data on the basis of a percentage of equivalent adult single fare for observed NEC journeys. This is then reduced by a ‘discount factor’ to account for NEC passengers’ expected use of multi-journey/discounted products (daily, weekly, season tickets). An annual budget cap is also applied to the Scheme as a whole.

Four out of the six bus operators who provided feedback as part of the evaluation discussed the reimbursement rate. Of these, three noted that the reimbursement rate had generally decreased each year or felt that this was now set too low. One also indicated that it caused uncertainty each year until the rate of payment was confirmed, making it difficult for operators to plan ahead.

Three operators also expressed views about their understanding of the way the reimbursement rate is calculated. They suggested that, the use of the adult single fare as the starting point for the reimbursement calculation could mean that operators may increase this in order to maximise the reimbursement payment (even with the discount factor applied). Their view was that this would result in increasing fares for paying passengers, both widening the financial divide between concessionary cardholders and non-cardholders, and making bus travel less attractive to paying passengers. There was also a suggestion that differing passenger demographics and travel patterns, as well as fare policies could introduce disparities between operators. However, the methodology used to set the reimbursement rates prevents this from being the case.

Another issue raised by one operator was the current delay in the registration process to deliver an eligible service. They noted that, to be eligible for the Scheme, the service must be registered via the Traffic Commissioner but there were long delays in registrations being approved. Agreements had been put in place to allow services to operate as long as the application has been made, but operators still cannot claim the reimbursement for journeys made under the Scheme from Transport Scotland without the registration. This could result in operators not receiving reimbursement for several months, and was a source of frustration for operators.

One commercial operator also noted that the Scheme did not operate in isolation, with several concessionary travel cards in operation. This made it challenging for drivers to always know which rules applied:

Marketing and information provision

Bus operators generally felt that most members of the public were aware of the Scheme, and that cardholders typically were well informed about how to use the NEC. A few operators indicated that they actively marketed the Scheme themselves, having information on their website; joining in with specific campaigns, for example, post-Covid; conducting leaflet drops; and local advertising.

The most common way that survey respondents found out about the free bus pass, however, was through word of mouth (for example, from friends, family, colleagues, etc.); 47% said they heard about it this way. All other ways were mentioned by a minority of respondents, with the next most common options being from a GP or health worker (8%), and the internet (6%) (see Annex - Table 44).

Responses by card type were highly mixed. Disabled cardholders were much less likely to have found out about the free bus pass via word of mouth (25%) compared to those with an over 60 card (60%). Conversely, they were more likely to have heard about it from a range of other sources compared to those with an over 60 card. This included a GP/health worker (20%), the internet (9%), advocacy or support group (8%), and a social worker (5%). Whilst word of mouth remained the most common way of finding out about the free bus pass for those who had financial difficulties, they were less likely to say this (32%) compared to those managing well financially (55%). In addition, those who had financial difficulties were more likely to say they found out from a GP or health worker (19%) compared to those managing well financially (3%). Disaggregated results are at Annex - Tables 45-46).

The majority of survey respondents (86%) found it either fairly or very easy to find the information they needed and how to apply for their free bus pass. Those who held one of the disabled cards were slightly less likely to find it easy and more likely to find it difficult compared to those with an over 60 card. Results are provided in the Annex - Tables 47-48.

However, several comments were made across the interviews with support organisations and the focus groups regarding inconsistencies in the information that was available or proactively shared. One support organisation noted that the differences between the types of cards and eligibility for each was not well understood by the public and sometimes by staff providing support. They noted that many disabled cardholders thought they had to switch to the over 60 card upon turning 60, with some even being told this by application service staff. For those with companion cards this means losing the companion element. One registered deafblind adult explained that they had been told different things regarding their eligibility at the hospital, by a local charity and then again by the local library. Another sight impaired cardholder explained that when they had tried to find out more about the Scheme their local charity had been unable to help.

One bus operator also thought that the information about who is responsible for the Scheme could be made clearer. They noted that some cardholders thought that the bus operators were responsible for it or that they could help them with getting a card.

Another bus operator suggested that greater awareness raising was required among the public and stakeholders so that the requirement to have a valid NEC to access free bus travel was clearly understood. They noted that the rules for operators were clear regarding the need for a card, in working order, but that these requirements were perhaps not clear to passengers or other stakeholders. For example, there were reports of notes being provided by library staff to confirm that a cardholder’s replacement card had been ordered in order to secure free travel in the meantime. This can create difficult situations for drivers who need to implement the rules of the Scheme and take action to stop fraud, but still support those that have made a genuine mistake or are having a genuine problem with their card.

Some focus group participants and one bus operator also questioned whether there was sufficient information about the full scope of the use of the NEC. In particular, that it could be used Scotland-wide, including on coaches for long distance and inter-regional journeys. It was felt that greater awareness raising may be useful in this respect.

Similarly, some survey and focus group respondents felt that there was a lack of clear information about if and how the NEC could be used to access discounts on other modes of public transport. It was suggested that more could be done to raise awareness of this:

A small number of focus group respondents also indicated that they were unsure about eligibility requirements for the companion element of the Scheme. They felt that information on eligibility and how to apply for this could be better advertised.

Focus group participants also suggested that more general information about the Scheme could/should be more readily available in non-digital formats to ensure inclusivity. It was felt there was perhaps too much reliance on online methods, which were often inaccessible to older people, those with certain disabilities, and those who experienced connectivity issues or digital poverty. There were also calls from support organisations and survey respondents for information to be made available in different formats, such as BSL and easy read.

The application process

Survey respondents were asked a series of questions about the application process. Responses to most questions can be found in the Annex - Tables 49-52, while overall views are outlined below.

Most respondents (85%) said they had found the application process they used either fairly or very easy, while only 6% had found it either fairly or very difficult (see Table 25). There were also very few differences when considered by the types of applications used.

There were, however, differences by card type and how respondents were doing financially (see Annex - Tables 53-54). Those with an over 60 card were more likely to find the application very easy (58%) compared to those with a disabled card (31%). Meanwhile those with a disabled card were more likely to find the process either fairly or very difficult (14%) compared to those with an over 60 card (3%). Similarly, those who were doing well financially were more likely to say the application process was very easy (59%) compared to those who had financial difficulties (33%). Meanwhile, those with financial difficulties were more likely to say that the process was fairly or very difficult (12%) compared to those doing well (4%).

Table 25 Ease of the application process by type of application (survey respondents)

Several survey respondents felt that the application system was overly complex and not user friendly, especially for those with disabilities:

Similarly, the main challenges experienced by focus group participants related to applying for one of the disabled cards. These applications were said to require more paperwork/supporting evidence, and the process was therefore more protracted and difficult.

Both survey respondents and focus group participants stressed the need to maintain a choice of different ways to apply, including online, by post, in person and by phone. However, there was concern that too much of the application process had moved online, with applicants finding it harder to access phone or in person routes.

Renewal and replacement process

Disabled cards contain an expiry date (maximum of three years from the date of issue) and therefore need to be renewed to ensure cardholders are still eligible. The over 60 card does not have an expiry date and does not need to be renewed. Any lost, damaged, or faulty cards need to be replaced.

Just under half of the survey respondents (42%, 1,044) indicated that they had renewed or replaced their card at some point. Of the 689 respondents who said they had renewed their card, most (77%) held a disabled card. Whilst the over 60 card does not expire, 161 respondents with this type of card stated that they had renewed it. Of those who had renewed their card, 26% indicated that they had been notified of the need to do this, while 61% were not notified. Around three quarters (74%) of those who had either renewed or replaced their card had found the process either fairly or very easy, compared to 16% who had found it either fairly or very difficult. When disaggregated by card type, Table 26 shows that disabled cardholders found the process less easy and more difficult compared to those with an over 60 card. Overall, 64% of disabled cardholders felt the process was fairly or very easy (compared to 88% of over 60 cardholders), while 24% felt it was either fairly or very difficult (compared to just 6% of over 60 cardholders).

Table 26 Ease of getting a new or replacement card by type of card held

Focus group respondents noted considerable variations in the renewal processes between local authority areas and card types. Some disabled cardholders indicated that they benefited from a more automatic renewal process within their area (given their type of card and disability). Others with the same card type and similar disabilities, however, reported much more rigorous renewal processes, including essentially having to submit a new application each time. There were calls for this to be standardised across the country.

Among those who discussed problems, these tended to relate more to the renewal process rather than replacements. It was noted that the information about how to renew was unclear and that there was a lack of contact or engagement within some local authorities to provide advice and support:

Survey respondents, focus group participants and bus operators noted that expiry dates on disabled cards were particularly problematic for some people. Those with particular disabilities noted that the expiry date was difficult to see or they struggled to remember it, meaning they often did not realise it had expired until it was rejected by a ticket machine onboard a bus. As such, a reminder letter or email (or auto-renewal and re-issuing the card where appropriate) would be helpful.

Similarly, where conditions are lifelong, will not improve, or where they are known to be degenerative (or where a lifelong disability benefits award has been made), many felt that there should be no expiry date on the card and no need for renewals:

Several survey respondents and focus group participants also stressed that not all disabled people who are eligible for the Scheme are in receipt of disability benefits from either the Department for Work and Pensions (DWP) or Social Security Scotland (SSS). They noted that the application and renewal process was particularly difficult and stressful in these situations as cardholders were required to gain proof or signed agreement from medical professionals each time.

The requirement to renew the card every few years was also highlighted in focus groups and interviews with support organisations as an issue that disabled cardholders took into account when they reached the age of 60. It was suggested that the need to renew regularly was off-putting and challenging, and so some cardholders switch to the over 60 card in order to avoid the renewal process. However, for those with a companion card, they had to make a decision between continuing to renew regularly (despite being aged 60+) in order to retain the companion element, or lose the companion element and switch to an over 60 card to avoid the need to renew regularly.

A key issue for both survey respondents and focus group participants was to ensure a range of mechanisms were available for the renewal process. Several noted a preference for an online form rather than corresponding about renewals/ replacements by email. A dedicated online renewals and replacement form was also preferable to having to complete the main application again in full. Others were keen to ensure that easily accessible in-person services were in place, as well as a telephone helpline. A few cardholders also wanted dedicated support for particular conditions, e.g. deafblind people.