Submission to the Inter-Departmental Review
Group:
Review of Disabled Drivers and Passengers Tax Concession
Scheme
Introduction
A key principle underpinning the work of Comhairle (See Note) is the promotion of equality of access and inclusion. One of its functions is to assist and support people, particularly those with disabilities, in accessing their entitlement to social services. Equality of access requires the provision of a comprehensive range of support services to cater for individuals with a wide range of needs.
While there has been much emphasis in social cohesion programmes and in anti-poverty strategies on the concept of inclusiveness, it is not clear that the position of people whose access to services has already been impaired by physical, psychological, educational, linguistic, socio-economic, cultural and technological factors has changed relative to the population as a whole. Differences, based on ability/disability, age, class and geographical location continue to persist. Issues in respect of access to transport can only be adequately addressed in the context of equality of access to services.
People require different kinds of transport and mobility supports depending not only on the nature and extent of their disability but, also, on their income, place of residence, family circumstances, current and prospective employment status and their requirements in respect of training, education and social involvement. Transport support schemes should, therefore, operate in this broader context so as to cater for the complexity of people's needs. Any reviews of current schemes should not take place in isolation but should be done as part of an integrated package of support services, including transport, for people currently experiencing access disadvantage. In the context of a mainstreaming approach to service provision this comprehensive, integrated approach to transport support schemes is essential.
Principles of equality of access, participation, choice and citizens' rights require the adoption of an integrated and co-ordinated approach to disability issues. This in turn requires that all categories of people with disabilities experiencing transport and mobility difficulties under current methods of provision be identified and targeted for innovative service development. A developmental approach to transport provision should, therefore, be based on the following criteria:
- New strategies for transport and mobility supports
are required to cater for the needs of a wide range of
individuals and groups;
- There is a need to carry out an ‘inventory' of all
categories of people in the community who require
transport and mobility assistance and to address the
needs identified in a planned and programmed
way;
- It is necessary to avoid the trap of operating on a
‘first come/first served' basis;
- Resources should be allocated to meet the real costs of disabilities.
Role of the Disabled Drivers' and Disabled Passengers' Tax Concession Scheme
The Disabled Drivers' and Disabled Passengers' Tax Concession Scheme is one of a number of different arrangements which contribute to income maintenance for people with disabilities but which are mainly aimed at facilitating or improving mobility. We consider that the review of the scheme should be placed in this broader context and should take into account other arrangements and other reviews which are currently being conducted. In particular, the scheme should be seen in the context of the following:
- the review of Free Travel Scheme operated by the DSCFA, as it affects people with disabilities;
- the Mobility Allowance operated by the Health Boards;
- the Motorised Transport Grants provided by the Health Boards;
- the Working Group to be established under the Programme for Prosperity and Fairness on the question of a Cost of Disability Payment.;
- the commitments in the Programme for Prosperity and Fairness in relation to access to public transport for people with disabilities.
In the National Social Service Board (now part of Comhairle) Submission to the Review of Free Schemes carried out for the Department of Social, Community and Family Affairs, it was stated (in the context of free travel):
"For people with disabilities, there is a need to co-ordinate with other schemes run by other departments particularly the mobility allowance scheme, the travel to hospital scheme and the tax concessions for disabled drivers. At present, there is no co-ordination between any of these schemes.
A comprehensive travel package for people with disabilities should be examined. This could include the current free travel arrangements for those for whom it is suitable, an alternative mobility cash payment and a revamped scheme of tax relief for private car use. We understand that there is a group examining the tax reliefs for disabled drivers. The work of this group should be taken into account in the DSCFA review."
The DSCFA Review has now been published. It did not examine the question of a co-ordinated scheme for people with disabilities. There is a need for a comprehensive package of transport/mobility measures for people with disabilities.
Unlike the DSCFA Free Travel Scheme, the tax concessions scheme is exclusively for people with disabilities. So also are the Motorised Grant Scheme and the Mobility Allowance. All these schemes should be reviewed together. They all recognise the additional costs which apply by virtue of disability and could be seen as an element of a Cost of Disability Payment.
The Disabled Drivers' and Disabled Passengers' Tax Concessions Scheme is of considerable benefit to the relatively small number of people who meet the very strict medical criteria - approximately 5,400 at present. Individual drivers who benefit from the scheme effectively get an annual subsidy of over £4,000, regardless of means. This is in contrast to the small Mobility Allowance payable by health boards.
The scheme, quite rightly, has a formal appeals system. The other mobility schemes do not. All such schemes should have a formal appeals mechanism.
This scheme involves tax foregone equivalent to about half of the cost of the DSCFA free travel scheme which benefits about half a million people. The actual benefits are not, of course, directly comparable.
As this scheme is tax based, the costs arise from the revenue foregone. Traditionally, such expenditure has been subject to less scrutiny than direct payments. Tax based expenditures should be subject to exactly the same level of scrutiny as direct payments as recommendedby the Commission on Taxation.
We understand that doubts have been expressed by the EU about the VAT and fuel excise duty aspects of the scheme and it may be that the EU may take the view that its continuance is impossible. Such tax-based schemes do not exist in other EU countries.
We consider that a Cost of Disability payment should more appropriately be a direct payment to a much wider group of people with disabilities.
Extension to other groups
Eligibility for the Disabled Drivers' and Disabled Passengers' Tax Concession Scheme is restricted to a small group of people - those who are severely and permanently physically disabled. The strict medical criteria exclude a wide range of people with various disabilities who need assistance with transport and mobility costs. Groups who are not eligible have been campaigning for inclusion - there is a strong campaign at present by other groups, particularly blind people, for inclusion. While the people who benefit are clearly in need of a mobility/transport subsidy, there are many other people with disabilities whose need for a transport or mobility subsidy is equal or may sometimes be greater.
The scheme is based in an implied assumption that people who do not qualify are capable of using public transport. This is patently not the case. The scheme does, therefore, substantially benefit one group while not providing for any of the transport needs of other, equally needy groups.
We believe that the mobility schemes should all be amalgamated into a co-ordinated mobility or transport subsidy on the basis of an individual needs assessment.
A transport/mobility subsidy
We consider that there should be a transport/mobility subsidy available to a much wider group of people with disabilities. This should be a direct payment rather than a tax expenditure and should be based on an individual needs assessment.
The motorised transport grant which is payable by health boards is a more targeted, and much lower, benefit. It is granted on the basis of need. People with very severe disabilities are eligible if they need a car to get to work or, in some cases, if they live in a very remote area. It is also means tested.
One criterion for the motorised transport grant is that the disability must be such as to impede the person from using public transport. This seems to be a reasonable criterion. A transport/ mobility subsidy has to have due regard to the public policy of promoting the use of public transport. At present, public transport is largely inaccessible to severely disabled people. However, plans set out in the Programme for Prosperity and Fairness and the National Development Plan should result in a significant improvement in this situation. Nevertheless, there will continue to be people with disabilities who will need private transport.
It is public policy to try to maintain people with disabilities in the community. A transport/ mobility subsidy would contribute to that aim.
We believe that a transport/mobility subsidy is an essential element of a Cost of Disability payment and should be examined in that context.
An Integrated and Co-ordinated Approach
The purpose of the Review of the Disabled Drivers' and Disabled Passengers' Tax Concession Scheme is to identify whether and to what extent the scheme should be modified to take account of whatever anomalies currently exist. The review group includes the Department of Justice, Equality and Law Reform, the Department of Finance, the Department of Health and Children and the Revenue Commissioners. It does not include the Department of Social, Community and Family Affairs. The Working Group on a Cost of Disability Payment will be led by the Department of Health and Children and will include representatives from the Department of Social, Community and Family Affairs. It is important that the reviews of existing schemes and the consideration of new initiatives take place in a co-ordinated and integrated manner with active participation by all the relevant agencies.
Comhairle is the new national agency responsible for the provision of information, advice and advocacy on social services and combines all aspects of the work of the National Social Service Board (NSSB) and the information function of the National Rehabilitation Board (NRB). Comhairle provides information and advice on the broad range of social services via the national network of Citizens Information Centres (CICs), Comhairle offices and the Citizens' Information Database (CID). During 1999 the national network of CICs (85 centres) dealt with 240,000 queries from members of the public.
