Consultation on the Blue Badge Scheme in Wales: Eligibility and Implementation

1. Introduction

1.1 I am a responding to this consultant on the basis that I am a concerned individual.            However, in my employment I assist many people to apply for a blue badge. The    applications that I assist with are a combination of those made under the      automatic        criteria, those made on the basis of a permanent walking disability and those made            on the basis that the individual has a temporary, but significant, walking impairment           that it likely to last for at least six months.

2. The Impact of Extending the Criteria

2.1 The main impact on extending the criteria is the increased pressure that this could           put on the availability of Blue Badge parking bays, particularly in hospitals. In some         hospitals supplies of these bays are insufficient and badge holders can have difficulty        in parking.

3. Is further Extension to the Criteria Necessary?

3.1 The bulk of the applications that I assist with relate to that of cancer patients who can      be awarded a blue badge on a temporary basis so long as their walking impairment            is likely to last a minimum of 12 months. This extension was granted following the     last consultation in 2016. This is an incredibly valuable extension that has benefited      the lives of many people that I work with, not only has it made their visits to hospital        significantly easier, but it has given them freedom that many people lose when their           mobility is impaired.

3.2 However, some people who are diagnosed with cancer have treatment that will last a       shorter period, for example 6 months, and whose mobility may be impaired for a         further three months following this. This then means that they are unable to   apply for a blue badge on the basis of cancer treatment because their mobility is           unlikely to be impaired for the full 12 months, even though their mobility will be      significantly impaired for some time. Cancer treatment, no matter the length of the       treatment, can be gruelling and I would advocate reducing the 12 month period     that      restricts cancer patients.

4. Practical Implementation and consistency

      4.1The biggest single issue that I have experienced with the Blue Badge scheme in   Wales is the lack of consistency with the application of the rules. Each Local      Authority operates in such a different way that as an adviser the only way that I can      keep track is by keeping a spreadsheet.

    4.2  The lack of consistency among Local Authorities leads to much unfairness. For     example, in Cardiff, the application procedure and accepted evidence is very straight    forward, reasonable and Blue Badges are issued quickly when approved.          However,         in some Local Authorities the process is complex (I understand that one    Local   Authority has five different application forms) and can be lengthy. I applied for             some Blue Badges for applicants in Carmarthenshire on the 15^th January 2019 and          they are still waiting for these.

  4.3     One of the variations between the schemes is whether a face to face appointment is        required. This requirement can be very difficult for people firstly because of mobility             issues. Without a Blue Badge some of the Local Authority offices can be very difficult        to access with people expected to walk quite a distance to get to the office. An          additional issue with face to face appointments is that many cancer patients (and in           particular those with haematological malignancies) are immunosuppressed and are       told by the health care professionals involved in their care that they should not go to         public places such as           these. Finally, some people are not physically well enough to          attend an appointment, and arguably these are the people who would most benefit        from a Blue Badge. However, the physical attendance requirement prevents them         from benefiting from the scheme.

4.4       When seen at the face to face assessment, the applicant is not seen by an           occupational therapist or anybody suitably qualified to make an assessment of   mobility, they are seen by a customer services officer. In my mind, this makes the attendance at the office pointless as it is unreasonable for somebody with no       knowledge of mobility impairments to be making these assessments.

4.5       Another inconsistency is the type of medical evidence that Local Authorities will    accept. Some Local Authorities are very reasonable in their approach but other sadly    are not. Unfortunately, Carmarthenshire County Council will not accept medical          evidence from a hospital consultant or clinical nurse specialists under any        circumstances. In my experience, where an applicant is applying for a Blue Badge             under the temporary criteria they insist on each applicant having a thorough          assessment by an occupational therapist. This seems both unnecessary and costly    given that the applicant’s healthcare team will have a much wider knowledge of their     mobility. It seems totally illogical to disregard the opinions of healthcare       professionals.  Furthermore, this causes issues and delays to the issuing of a badge.             Where an applicant is unable to attend an assessment, a home visit must be        arranged and they seem to be taking a very long time. Indeed, only today has one of my clients phoned me to tell me that she told the Local Authority not to pursue the      application as it was taking too long and causing her too much stress. We submitted an email application for her on the 7^th January 2019. Sadly, had her application been             submitted to a different Local Authority, she would have received her Blue Badge             within about two weeks.

5.         Support and Information available to applicants in Wales

5.1       Many of the patients that I meet do not know that they may be eligible for a Blue   Badge until they have either had a conversation about their mobility with me or with             one of my NHS colleagues.

5.2       In terms of being able to access information about Blue Badges online, I personally          find that some Local Authority websites are easier to navigate than others and on   some it is really difficult find application forms, or indeed any useful information on         this topic, on some sites.

5.3       It is not currently possible to apply for a blue badge on the basis of a temporary, but         significant walking on the .gov website. If this is attempted then the applicant is          advised that they are not eligible for a Blue Badge (as is the case in England), this is       misleading for Welsh applicants and may put people off applying.