Dr. Amie Lajoie:

I thank the Vice Chairman and committee members. The Money Advice & Budgeting Service very much welcomes the opportunity to contribute to the committee’s deliberations on this important topic.

The disabled drivers and disabled passengers, DDDP, scheme operated by the Office of the Revenue Commissioners provides a range of supports towards the purchase and operation of specially constructed and adapted vehicles by disabled drivers and passengers, including tax relief on vehicle registration tax, VRT, and VAT, an exemption from motor tax and an annual fuel grant. We flag that direct commentary on the logistics and tax implications of the scheme is not in the MABS area of expertise. However, as an essential front-line service with a holistic approach to assisting clients with their immediate debt problems and supporting them to become financially independent in the long term, we can offer in-depth insight into the ways this scheme and related welfare supports work on the ground. In addition, after 30 years of promoting financial inclusion for Ireland’s most marginalised communities, MABS is in a unique position to comment on the ongoing challenges faced by persons with disabilities who access our services. It is through this context that we position our statement and engagement with the committee today.

In preparation for the meeting, MABS support issued a comprehensive survey to all MABS staff and money advisers around the country, and consulted with our funder, the Citizens Information Board, CIB. The CIB social policy team sent us collated data arising from transport and disability queries to local citizens information services, CIS, to which we also refer.

To start, we will list the five primary issues highlighted by local MABS services and-or CIS regarding the DDDP scheme as it currently operates. We include examples of our clients’ lived experiences to illustrate these points. The first issue relates to the medical criteria for the scheme. The DDDP scheme is inaccessible for many due to the restrictive medical criteria for accessing the primary medical certificate, PMC, necessary for approval. If an initial PMC application is rejected, an appeal may be lodged to the disabled drivers medical board of appeal. To qualify, an applicant must satisfy at least one of six medical criteria that focus predominantly on physical disabilities, particularly a lack of limb function. This criterion is exclusionary for persons with other disability types, including chronic illnesses, brain or neurological conditions, cardiovascular diseases and so on. For example, a money adviser from north Dublin spoke of a client with chronic obstructive pulmonary disease, COPD, who uses a wheelchair and is on oxygen. She is unable to walk unaided or more than a few steps at once. Her application for a PMC and subsequent appeal were denied as she was deemed to have use of her legs.

The second issue we wish to raise is the appeals process. When operational, the primary medical certificate, PMC, appeals process requires persons to travel to Dublin for an in-person assessment. This can often be extremely challenging, if not impossible, and costly for those clients who live far away. A client in a local citizens information service, CIS, office lost her appeal after she was unable to travel the five-hour journey from her home to attend an assessment in Dublin. The client lives alone and had no means of personal transport.

The third issue we want to flag is the scheme being exclusionary due to cost. Even if their clients satisfy the physical requirements, money advisers highlighted the majority of their clients cannot access the scheme as they cannot afford the purchase of a vehicle, let alone maintenance, even with tax reliefs and rebates. Many MABS clients with disabilities rely solely on social welfare payments to live, and face increased living costs already, in particular, for transport. This was highlighted in the most recent report on the increased costs for persons living with disabilities in Ireland published in November last year by the Department of Social Protection. A money adviser in Cork discussed how her clients who are wheelchair users must take taxis to medical appointments as public transport is unavailable and inaccessible. While they can get their taxi fare reimbursed by the local community welfare office this could take up to two weeks to process. In the interim, she has seen clients opt to go without food in order to cover these costs.

The fourth issue we want to raise is the inflexibility of the scheme. Citizens information services identified how the disabled drivers and disabled passengers scheme can also be restrictive, for instance, when there is a sudden change of familial circumstances. Family members of disabled passengers can be eligible for the scheme if they are living with, and responsible for, their transport, and own a vehicle for that reason. However, problems arose for one CIS client with disabilities when her husband died. He had been the driver of her specially adapted vehicle with the vehicle registration tax and VAT rebates attached. The client’s son-in-law was available to take over driving responsibilities but in this case the client had to explore transferring ownership of the vehicle to her son-in-law, which was not what she had wanted.

The fifth and final issue we raise is the scheme's applicability to replacing previous grants offered by the Government. In 2013, the Government closed the mobility allowance and motorised transport grant schemes to new applicants. The DDDP scheme, therefore, took on an increasing importance for people with disabilities. However, the scheme, in its current guise, is not effective to provide relief to those who truly need it, in particular low-income persons. MABS money advisers called for the return and-or replacement of the prior grants and the mobility allowance, in particular, arguing it contributed greatly to their clients’ overall health and well-being, easing financial burdens for transport and providing increased opportunities for participation and social engagement. Since 2013, citizens information services have also repeatedly highlighted this issue and the Citizens Information Board raised this in successive pre-budget submissions.

It is important to draw connections between these points and underlying issues of financial inclusion faced by persons with disabilities. Research from the European Disability Forum found that 38.1% of persons with disabilities in Ireland are at risk of poverty and social exclusion, a number that has grown since 2010 and is worryingly higher than the EU average of 28.7%. MABS services work to help alleviate financial pressures for those who are struggling and we find that, particularly for clients with disabilities, there are a number of barriers to accessing available social welfare supports, including but not limited to the DDDP scheme. This includes a lack of knowledge of rights and entitlements. Most clients are not aware of what they are entitled to until they come to MABS and-or citizens Information services and that they have the right to appeal a decision to reject their applications for social welfare. Also, clients with disabilities face increased difficulties with the required online applications due to digital exclusion, not owning or able to afford the necessary smart devices, lack of home broadband access, which is particularly the case in rural areas, and lower than average levels of digital literacy.

Persons with disabilities also face increased household expenses, for instance, people may have to keep warm when they are not mobile and-or they might be homebound and require continuous electricity, lighting and so on, and, therefore, are even more sensitive to rises in energy prices than the general population. Lack of accessible public transport, in particular in rural areas, leads to the reliance on taxis and personal transport options that, for many, are simply too expensive. Unfortunately, we would posit that challenges have exacerbated in recent months due to Covid-19 and the spike in the cost of living. Individual actions from our clients in terms of budgeting and entitlement maximisation are becoming insufficient in the face of insurmountable structural barriers.

We would list a number of direct actions to support the increased financial inclusion of persons with disabilities and, in turn, importantly, combat exclusion. They include the following. The extension of employment supports and awareness of supports to enable those with a disability to find meaningful employment if they so choose. This involves allowing retention of the medical card solely for medical need if working and regardless of income level. There is a need to provide a savings incentive scheme for all on social welfare, including those with disabilities; to support the training of front-line staff to assist those with disabilities with specialised needs, including post offices, banks, credit unions and public services; to enhance educational and financial literacy incentives, for example, fully funded third level courses with extra supports that have occupational outcomes; the provision and long-term accessibility of non-fee and basic bank accounts with preferential overdraft and loan rates; and available interest-free loans for capital spends such as housing adaptation, equipment purchases, vehicle adaptation, disability aids and so on.

We strongly support the efforts of this committee to examine the DDDP scheme and further promote the full participation and financial inclusion of persons with disabilities. We look forward to discussing these matters further.