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B l u e B a d g e e l ig ib il it y a s s e s s m e n t:
    In d e p e n d e n t R e v ie w f in d in g s

                   Neil Taylor
       Integrated Transport Planning Ltd.
Background

 Extensive independent review of Blue Badge administration
  and assessment good practice in England for DfT...
    Review of 33 local authorities      Sep ‘09 – Sep ’10
    Evaluate CoE Programme              Sep ‘09 – Sep ‘10
    Pilot emerging good practices       Sep ’10 – Jan ‘11
    Prepared updated guidance for DfT   June 2011
    Final report published              August 2011
National Blue Badge scheme data
 2010 DfT Blue Badge scheme stats...
      1,053,000 BB applications (418,000 new / 635,000 renewal)
      86% of new / 93% of renewal applications accepted
      906,000 badges issued (558,000 subject to further assessment)
      349,000 successful new applications (590,550 renewal)
      BB acceptance rates range from 91% - 71% by region
      DfT estimate 300,000 medical assessments in 09/10

 2011 DfT Blue Badge scheme stats.....
    939,000 badges issued (571,000 subject to further assessment)
    324,000 successful new applications
1: Scheme publicity and information
             •   Provide inf ormation f or applicants, f or example online and in printed literature.
             •   Signpost potentially eligible people to the Blue Badge application pathway.
             •   Raise public awareness on the Blue Badge Scheme’s purpose and who is entitled to one.


    IMA’s influence on ‘The system’
             2: Handling new/renewal applications
             •   Application f orms available in print & online with clear submission mechanism
             •   Of f er support with completing the f orms & request proof of ID and address.
             •   Anti-f raud declarations and provision of applicant’s consent to share inf ormation.


             3: Eligibility determination
             •   Processing application f orms when they arrive with the local authority.
                                                                          Local Authority Blue
             •   Check proof of identity/address and determine eligibility assessment pathway.
                                                                               Badge teams
                                                   Legislation and
3a: Without further
                                 3b: Subject to    guidance
                                                  further assessment        (152 local systems)
assessment                       •   Desk-based assessment of self -reported inf ormation
                                 •   Telephone contact with applicant (as required)
•   Check proof of
                                 •   Ref er applicant f or mobility assessment with OT/Physio (as required)
    entitlement
                                 •   Seek specif ic inf ormation f rom applicant’s healthcare prof essional (as required)
•   Issue/ref use Blue
                                 •   Site visit to organisational Blue Badge applicant’s premises (as required)
    Badge
                                 •
                                                                     Broad set of
                                     Determine eligibility based on recommendations & evidence
                                                                    Blue Badge
                               The Blue                             Scheme
      4a: Administration of unsuccessful applications
                                 Badge                             processes
      • Write to applicant, explaining grounds f or ref usal and providing an opportunity f or a review, or complaint
                                Scheme
      • If required, lead applicant through the review or complaint process. If successf ul ref er applicant step 4b


                                (National
      4b: Administration of successful applications
      •
                                 system)
          Applicant to receive Df T’s ‘Blue Badge Scheme: rights and responsibilities’ leaf let and sign declaration
          on terms of use and awareness of their duty to return the badge if their circumstances change
      •   Applicant to pay Blue Badge issue f ee and be promptly issued aBlue Badge & parking disc

                                                                     Localised
5: Ongoing administration                                            practices
•   Manage standard renewals, with a reminder letter 3 months bef ore expiry
•   Manage renewals of lost/damaged and stolen badges
•   Request badges f rom Blue Badge holders registered as deceased
•   Share inf ormation with parking enf orcement teams where abuse of the Blue Badge is suspected
                                                    Outputs (number of badges
6: Proactive Blue Badge enforcement                 awarded/refused)
•   Include Blue Badge checks in routine parking enf orcement inspections
•   If required, monitor suspected Blue Badge abuse/f raudulent users
•   If required, withdraw the Blue Badge f rom f raudulent holders/users
Critical dependencies
 BB application form:
    Does it provide useful information about applicant’s condition?
    Declarations – information sharing / IMAs

 Appeals procedures:
      Detailed refusal letter heads off many appeals
      Separate appeal ‘reviews’ from ‘complaints’
      Only ever need to reassess following complaint against procedure
      No legal requirement to carry out appeals

 Re-applications
    Does the applicant need to be reassessed?
    Opportunity to check fluid conditions
Early findings were bewildering...
 Multitude of different approaches to BB admin & assessment

 Partly due to different LA organisational structures/geography

 Many authorities aiming to reduce BB scheme costs...

 ... but some seemed to have gone too far:
    We use a desk-based scoring system (‘some people probably lie’)

    No IMAs at all (‘admin staff meet borderline applicants’)

    No renewal reminders (‘too expensive’)
Detailed results made case for IMAs...
 63% of BB applicants are subject to further assessment

 Most have some form of walking impairment

 Research study pilots found that using IMAs...
    Reduce costs by 30% compared to GP assessments

    Reduce award rates from 95% (GP) to 70%

    Achieve lower rates of appeal (20% IMA, 39% GP)

    Result in fewer successful appeals (21% IMA, 28% GP)

    Accelerate the eligibility decision-making process
And prompted new legislation...
“In order to ensure a fairer allocation of badges, we have
therefore amended legislation to prescribe that eligibility
under 4(2)(f) be confirmed through use of an independent
mobility assessment unless the authority is satisfied in a
particular case that it would not assist it in deciding whether
the applicant was eligible (i.e. that it is self-evident that the
applicant is eligible or ineligible). The legislation also
prescribes the use of Independent Mobility Assessments
(IMAs) in assessing eligibility under 4(2)(g) which covers
temporary badges to people “unable to walk or
virtually unable to walk by reason of a temporary or
substantial disability which is likely to last for a
period of at least 12 months”.

Local Authority Circular November 2011
Other key findings also helpful...
 OTs/Physios are most appropriate healthcare professionals

 Suggested caseloads for healthcare professionals:
    Assessment: 30 mins, Decision & reporting: 10 mins

    7-8 applicants /day maximum

 IMAs have been implemented successfully by all types of LA

 Desk-based assessments are effective filtering tools
    Identify clearly eligible/ineligible applicants

    Piloted approach was 91% accurate compared to IMAs
Eligibility assessment ‘Core principles’
 Developed for DfT BB Scheme Guidance in England

 A way of enabling DfT to emphasise to English local
  authorities what should go into an assessment, without
  prescribing a specific approach.
 Tested through piloting and rigorous evaluation

 Supported through legislation coming into force in Sept 2012
Core principles – Desk Assessments
 Get OTs/Physios involved in the design & staff training

 Devise an objective quantitative scoring mechanism

 Can be completed by (trained) administrative staff members

 Require applicants to fully complete BB application form
Core principles – Desk Assessments
 Cross-check self-reported information on walking ability with
  disability/condition and local health services accessed
 Additional information can be sought by phone

 Look up on a map where applicant walks to from their home
Overview of desk-based assessments
Pro’s:
 Offers uniformity of outcomes

 Significantly reduces assessment costs

Con’s:
 Good filtering tool but not suitable for making a decision on
  every applicant.
 Recourse to an IMA where a decision can’t be made
Core principles – IMAs
 Full design & delivery by health professionals (OT/Physio)

 Check applicant’s ID at start of assessment!

 Cross-check information from applicant’s application form

 Observe & record the applicant’s manner of walking
Core principles – IMAs
 Use functional movement tests as appropriate

 Observe and time the applicant walking a known distance

 Observe resting, pauses and amount of time taken to walk

 MRC dyspnoea scale for breathlessness & observe
Core principles – IMAs
 Ask applicant about where & how they normally walk

 Consider (correct) use of walking aids – could an aid help?

 Discuss (self-reported) pain and observe applicant
Core principles – IMAs
 Decision is a holistic view of all information gathered...

   “Consider each aspect of walking (pain, breathlessness,
   speed, distance, use of walking aids and manner of walking)
   first in isolation, and then in combination, to reach a decision
   as to whether they combine to mean the applicant is unable
   or virtually unable to walk.”
Overview of IMAs

Pro’s:
 Most accurate way of determining eligibility

 Applicants feel their case has been fully considered

 Reduces number of consequent appeals

Con’s:
 Extends the decision-making process

 Expensive and time consuming for all parties
Golden rules
 Always refer to the eligibility criteria for BB Scheme

 Ensure your assessment regime complies with the following
  hierarchy of rules/guidance:

   1. Primary legislation

   2. Secondary regulations

   3. Code of Practice & Process Model

   4. Research evidence
Thanks for your time today...



ITP’s independent review of Blue Badge Scheme for DfT:
http://www.dft.gov.uk/publications/blue-badge-good-practice-review



 Neil Taylor                  T: 0115 988 6903
 ITP Nottingham               E: taylor@itpworld.net

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Assessment - Integrated Transport Planning Ltd

  • 1. B l u e B a d g e e l ig ib il it y a s s e s s m e n t: In d e p e n d e n t R e v ie w f in d in g s Neil Taylor Integrated Transport Planning Ltd.
  • 2. Background  Extensive independent review of Blue Badge administration and assessment good practice in England for DfT...  Review of 33 local authorities Sep ‘09 – Sep ’10  Evaluate CoE Programme Sep ‘09 – Sep ‘10  Pilot emerging good practices Sep ’10 – Jan ‘11  Prepared updated guidance for DfT June 2011  Final report published August 2011
  • 3. National Blue Badge scheme data  2010 DfT Blue Badge scheme stats...  1,053,000 BB applications (418,000 new / 635,000 renewal)  86% of new / 93% of renewal applications accepted  906,000 badges issued (558,000 subject to further assessment)  349,000 successful new applications (590,550 renewal)  BB acceptance rates range from 91% - 71% by region  DfT estimate 300,000 medical assessments in 09/10  2011 DfT Blue Badge scheme stats.....  939,000 badges issued (571,000 subject to further assessment)  324,000 successful new applications
  • 4. 1: Scheme publicity and information • Provide inf ormation f or applicants, f or example online and in printed literature. • Signpost potentially eligible people to the Blue Badge application pathway. • Raise public awareness on the Blue Badge Scheme’s purpose and who is entitled to one. IMA’s influence on ‘The system’ 2: Handling new/renewal applications • Application f orms available in print & online with clear submission mechanism • Of f er support with completing the f orms & request proof of ID and address. • Anti-f raud declarations and provision of applicant’s consent to share inf ormation. 3: Eligibility determination • Processing application f orms when they arrive with the local authority. Local Authority Blue • Check proof of identity/address and determine eligibility assessment pathway. Badge teams Legislation and 3a: Without further 3b: Subject to guidance further assessment (152 local systems) assessment • Desk-based assessment of self -reported inf ormation • Telephone contact with applicant (as required) • Check proof of • Ref er applicant f or mobility assessment with OT/Physio (as required) entitlement • Seek specif ic inf ormation f rom applicant’s healthcare prof essional (as required) • Issue/ref use Blue • Site visit to organisational Blue Badge applicant’s premises (as required) Badge • Broad set of Determine eligibility based on recommendations & evidence Blue Badge The Blue Scheme 4a: Administration of unsuccessful applications Badge processes • Write to applicant, explaining grounds f or ref usal and providing an opportunity f or a review, or complaint Scheme • If required, lead applicant through the review or complaint process. If successf ul ref er applicant step 4b (National 4b: Administration of successful applications • system) Applicant to receive Df T’s ‘Blue Badge Scheme: rights and responsibilities’ leaf let and sign declaration on terms of use and awareness of their duty to return the badge if their circumstances change • Applicant to pay Blue Badge issue f ee and be promptly issued aBlue Badge & parking disc Localised 5: Ongoing administration practices • Manage standard renewals, with a reminder letter 3 months bef ore expiry • Manage renewals of lost/damaged and stolen badges • Request badges f rom Blue Badge holders registered as deceased • Share inf ormation with parking enf orcement teams where abuse of the Blue Badge is suspected Outputs (number of badges 6: Proactive Blue Badge enforcement awarded/refused) • Include Blue Badge checks in routine parking enf orcement inspections • If required, monitor suspected Blue Badge abuse/f raudulent users • If required, withdraw the Blue Badge f rom f raudulent holders/users
  • 5. Critical dependencies  BB application form:  Does it provide useful information about applicant’s condition?  Declarations – information sharing / IMAs  Appeals procedures:  Detailed refusal letter heads off many appeals  Separate appeal ‘reviews’ from ‘complaints’  Only ever need to reassess following complaint against procedure  No legal requirement to carry out appeals  Re-applications  Does the applicant need to be reassessed?  Opportunity to check fluid conditions
  • 6. Early findings were bewildering...  Multitude of different approaches to BB admin & assessment  Partly due to different LA organisational structures/geography  Many authorities aiming to reduce BB scheme costs...  ... but some seemed to have gone too far:  We use a desk-based scoring system (‘some people probably lie’)  No IMAs at all (‘admin staff meet borderline applicants’)  No renewal reminders (‘too expensive’)
  • 7. Detailed results made case for IMAs...  63% of BB applicants are subject to further assessment  Most have some form of walking impairment  Research study pilots found that using IMAs...  Reduce costs by 30% compared to GP assessments  Reduce award rates from 95% (GP) to 70%  Achieve lower rates of appeal (20% IMA, 39% GP)  Result in fewer successful appeals (21% IMA, 28% GP)  Accelerate the eligibility decision-making process
  • 8. And prompted new legislation... “In order to ensure a fairer allocation of badges, we have therefore amended legislation to prescribe that eligibility under 4(2)(f) be confirmed through use of an independent mobility assessment unless the authority is satisfied in a particular case that it would not assist it in deciding whether the applicant was eligible (i.e. that it is self-evident that the applicant is eligible or ineligible). The legislation also prescribes the use of Independent Mobility Assessments (IMAs) in assessing eligibility under 4(2)(g) which covers temporary badges to people “unable to walk or virtually unable to walk by reason of a temporary or substantial disability which is likely to last for a period of at least 12 months”. Local Authority Circular November 2011
  • 9. Other key findings also helpful...  OTs/Physios are most appropriate healthcare professionals  Suggested caseloads for healthcare professionals:  Assessment: 30 mins, Decision & reporting: 10 mins  7-8 applicants /day maximum  IMAs have been implemented successfully by all types of LA  Desk-based assessments are effective filtering tools  Identify clearly eligible/ineligible applicants  Piloted approach was 91% accurate compared to IMAs
  • 10. Eligibility assessment ‘Core principles’  Developed for DfT BB Scheme Guidance in England  A way of enabling DfT to emphasise to English local authorities what should go into an assessment, without prescribing a specific approach.  Tested through piloting and rigorous evaluation  Supported through legislation coming into force in Sept 2012
  • 11. Core principles – Desk Assessments  Get OTs/Physios involved in the design & staff training  Devise an objective quantitative scoring mechanism  Can be completed by (trained) administrative staff members  Require applicants to fully complete BB application form
  • 12. Core principles – Desk Assessments  Cross-check self-reported information on walking ability with disability/condition and local health services accessed  Additional information can be sought by phone  Look up on a map where applicant walks to from their home
  • 13. Overview of desk-based assessments Pro’s:  Offers uniformity of outcomes  Significantly reduces assessment costs Con’s:  Good filtering tool but not suitable for making a decision on every applicant.  Recourse to an IMA where a decision can’t be made
  • 14. Core principles – IMAs  Full design & delivery by health professionals (OT/Physio)  Check applicant’s ID at start of assessment!  Cross-check information from applicant’s application form  Observe & record the applicant’s manner of walking
  • 15. Core principles – IMAs  Use functional movement tests as appropriate  Observe and time the applicant walking a known distance  Observe resting, pauses and amount of time taken to walk  MRC dyspnoea scale for breathlessness & observe
  • 16. Core principles – IMAs  Ask applicant about where & how they normally walk  Consider (correct) use of walking aids – could an aid help?  Discuss (self-reported) pain and observe applicant
  • 17. Core principles – IMAs  Decision is a holistic view of all information gathered... “Consider each aspect of walking (pain, breathlessness, speed, distance, use of walking aids and manner of walking) first in isolation, and then in combination, to reach a decision as to whether they combine to mean the applicant is unable or virtually unable to walk.”
  • 18. Overview of IMAs Pro’s:  Most accurate way of determining eligibility  Applicants feel their case has been fully considered  Reduces number of consequent appeals Con’s:  Extends the decision-making process  Expensive and time consuming for all parties
  • 19. Golden rules  Always refer to the eligibility criteria for BB Scheme  Ensure your assessment regime complies with the following hierarchy of rules/guidance: 1. Primary legislation 2. Secondary regulations 3. Code of Practice & Process Model 4. Research evidence
  • 20. Thanks for your time today... ITP’s independent review of Blue Badge Scheme for DfT: http://www.dft.gov.uk/publications/blue-badge-good-practice-review Neil Taylor T: 0115 988 6903 ITP Nottingham E: taylor@itpworld.net

Editor's Notes

  1. Brief introduction to me Summarise what I am going to talk about today
  2. Mention explicit focus on IMAs, and the impact of CSR/change of government on shaping our thinking. By way of background, explain some details behind the good practice review and mention that it was led by ITP, but with support from: TAS Partnership Chartered Society of Physiotherapists College of Occupational Therapists UCL Jill Dando Institute of Crime Science Brunel University DWP DPTAC Explain briefly why pilots were necessary & mention ‘core principles’ concept
  3. At a national level, the Blue Badge stats underline how important IMAs are. Over 60% of new and renewal BB applications are considered under the subject to further assessment criterion. Award rates remain quite high (around 90%) but have fallen in recent years – notably they vary from region to region. Partly due to variable factors like the incidence and severity of disabilities, but also different BB assessment regimes. Attributable to the increased uptake of IMA practices among local authorities in England. Suggests what many suspected – we have been over-issuing Blue Badges as a result of the previous system of relying on GP assessments
  4. Came to adopt systems thinking approach – BB Scheme as a national system, the success/failure of which is dependent on the 152 issuing authorities local systems. It was quite clear to us that the way the 152 Blue Badge issuing authorities each determined the eligibility of BB applicants under the subject to further assessment criterion has a big impact on the output (number of badges refused/awarded) in the previous slide. At the local authority level it is also possible to see the impact that eligibility assessment practices have upon a local Blue Badge system. The IMA procedure exerts upstream pressure on the application form design and application handling process, as well as downstream pressure on the way unsuccessful applicants are notified about the outcome of their application, appeals and renewals procedures.
  5. Following on from this I have highlighted some critical dependencies for local authorities wishing to implement, or optimise, their IMA practice. BB Appn form – I would start from the DfT’s model form, and then consider whether each and every question in your application form tells you useful information. In designing this we considered a wide range of local authority’s application forms and sought to include only those questions which we felt added value to the eligbility assessment process. The model form was designed to inform both a desk-based and IMA eligibility assessment. Declarations are also key as they enable cross-checking of locally held information which could save local authorities money by negating the need for a BB applicant to undergo an IMA. Appeals – Really important that you get appeals right, because although we found there was a decrease in appeals following the move to IMAs, people will appeal and ask to be reassessed. Renewals – opportunity to save further public funds by identifying at the end of an assessment which applicants have very static impairments and do not need to be reassessed when they renew. Note that they will still have to renew, just not undergo re-assessment. Reassessment on renewal presents an opportunity to check fluid conditions that may have improved/changed.
  6. Very early in our study it was clear that a large number of different ways of determining the eligibility of BB applicants existed. Also very clear that some local authorities (normally through LEAN assessment) had tried to achieve savings to the way they deliver the BB scheme. Nothing wrong with this as an approach, but it did mean some had gone a bit too far – resulting in practices that make no sense from the customer’s perspective.
  7. Findings from the pilots of our independent review – published by DfT – indicate the extent to which LAs could be making savings, and improving the way they deliver the BB scheme. In particular, the average national cost of referring applicants to their GP takes 3-6 weeks and costs £30.30, compared unfavourably to that of an IMA taking 1-3 weeks to organise and costing £19.10 per assessment. Coupled to this, the better informed decision-making and consideration of eligibility criteria (we believe is borne out by the lower award rate) and lower rate of appeals suggests that IMAs are a more comprehensive and cost-effective approach.
  8. The independent mobility assessment should be conducted by a person who is recognised by the local authority as holding a professional qualification relating to the assessment of a person’s ability to walk, who is not employed or engaged in any other capacity as a provider of goods or services (including medical services) to the applicant and not related to the applicant. The assessment will be carried out on the applicant’s functionality rather than, as was previous carried out by GPs, on their medical diagnosis
  9. OTs and Physios have the necessary skills to consider the mobility of an applicant, in particular to assess their walking ability (but may require a slightly re-tuned mindset!) Caseloads were based on our findings from the pilots, and reflected an assessor having a structured assessment guide and decision-making proforma for reporting their recommendations. All available as appendices to our independent review final report. Pleasantly surprised to find desk-based assessments were pretty accurate (91%) when compared directly with the core principles IMA practice we piloted. Desk-based assessment proforma and guidance that we piloted is also available as an appendix to our final report. Key is to use desk-based assessments only as a means of filtering those applicants who clearly do/do not qualify for a badge, and send the rest for an IMA
  10. These desk-based assessment core principles were derived through our independent review and have been set out in DfT’s scheme guidance published in July 2011 (see Appendix F) Declarations are key to allowing cross-checking!
  11. Scoring mechanism used in our pilots is available in the appendices to our independent review Absolutely key to provide recourse to an IMA – desk-assessment is not perfect!
  12. See appendix G to July 2011 scheme guidance Explain range of functional movement tests
  13. Pain scales and MRC Dyspnoea scale are fairly common and explained in more detail in Appendix G of BB scheme guidance (July 2011) Dyspnoea scale devised by Medical Research Council – emphasised need to use existing standard measures, rather than creating new ones for BB assessment. Easy way to establish if an applicant experiences breathlessness... Important to cross reference all self-reported information against what you see in the assessment itself. Example of ‘extreme pain’ yet no visual signs of pain.
  14. Timing of walk over observed distance can be discretely done (RBKC example). Timing should include any resting/pauses (the duration of which can also be noted). Is the applicant using an aid? Could they use an aid to improve their walking?
  15. Quote is from Appendix G of DfT Scheme Guidance July 2011
  16. If I had some golden rules for sound assessment, then I would say they are...
  17. You can find our independent review, and the latest scheme guidance online at the address above. There is some information in your pack about ITP’s Blue Badge healthcheck service, which is informed by our work on the independent review. If anyone wants to discuss this, or ask questions about the findings from our study, then please feel free to come and chat at lunchtime.