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Blue badge application process - recommendations report

Councillor Malcolm Tullett

"This review looked at the difference in approval rates between applications for blue badges for visible and non-visible disabilities in Bracknell Forest.

"It began after some councillors received complaints about blue badge applications being refused, and a local newspaper article highlighted differences in approval rates between Bracknell Forest and other councils.

"Blue badges can be a lifeline for residents leading difficult lives. The inclusion of people with non-visible disabilities in the scheme in September 2019 extended that support to even more of our vulnerable residents. With a year of data to consider, this review was set up to understand and eliminate any inadvertent discrimination and make sure of fairness in the process.

"I would summarise the review objectives as ‘expectation, explanation and fairness’ and all recommendations are made with these principles in mind.”

- Councillor Malcolm Tullett, Chair: Wellbeing and Finance Overview and Scrutiny Panel

Recommendations

Adult Social Care is currently carrying out a wide-reaching review of the blue badge process. The following recommendations were made to the Assistant Director of Adult Social Care to be considered as part of the review implementation.

Future recommendations

The following recommendations are outside the departmental review. They are made to the Executive for future activities.

Good practice

Adult Social Care is carrying out a wide-reaching review of the blue badge process, looking at the process itself, where it sits within the council, training and engagement. The panel was pleased to hear this and is making relevant recommendations directly to the departmental review for a joined-up approach.

The new process goes live in September 2021 and the panel looks forward to an update on the results of the implementation in late September.

The review heard that the blue badge team carries out an internal review of any refusal decisions before the applicant is informed. Given the high impact of a refusal, the panel recognises this internal scrutiny as good practice.

Background information

During 2020 to 2021 Adult Social Care received 3 complaints relating to blue badges in Bracknell Forest.

Two related to non-visible disabilities and one related to a visible disability. The non-visible complaints were both investigated by the Local Government Ombudsman.

Approval rates in this report are based on data from a BBC freedom of information request:

  • 216 councils were asked for data about blue badge applications over the period 30 August 2019 to 17 August 2020
  • 73 councils (34%) provided a full response - Bracknell Forest was one of them
  • roughly half (109 councils) provided enough data to compare overall acceptance rates with rates for non-visible disabilities

Bracknell Forest had a difference in approval rates between all disabilities and non-visible disabilities of 43%, placing them 94th out of the 109 councils who provided data.

Review findings

Blue badges in Bracknell Forest

The Assistant Director, Adult Social Care noted that the council has consistently lower approval rates compared to the sample average, across both visible and non-visible disabilities:

  • rate of approval for all applications - 78% (compared to sample average of 83%)
  • rate of approval for non-visible applications - 35% (compared to sample average of 58%)
  • difference (all - non-visible) - 43% (compared to sample average of 25%)
  • proportion of badges issued that were for non-visible disabilities - 5.5% (compared to sample average of 4.2%)

The Assistant Director suggested this may be due to the rigorous process in place at Bracknell Forest.

Some councils carry out a desktop assessment only, which leaves room for greater variation and consequently may increase approval rates. Bracknell Forest always uses a team of qualified experts which may lead to more consistent, but generally lower, approval rates.

The Assistant Director is proud to use skilled assessors and is committed to making sure of the right capabilities for the future. Before the inclusion of non-visible disabilities, the majority of assessments focused on mobility. Assessing non-visible disabilities requires a wider range of expertise covering psychological, medical and neurological conditions. This review recommends the appropriate level of expert input for each assessment, particularly as some conditions are complex and rare.

The government guidance states:

“It is the responsibility of each local authority to ensure that badges are only issued to residents who satisfy one or more of the eligibility criteria set out in the legislation.”

Bracknell’s Assistant Community Services Officer - Occupational Therapy told the panel that the threshold for issuing a blue badge is high. There are no targets or an upper limit on the number of badges that can be issued. The panel recognised that if blue badges became widespread they would no longer convey a benefit due to pressure on spaces.

Of the 122 councils that provided relevant data, Bracknell Forest had the third highest proportion of applications for a non-visible disability (12%). A high proportion of non-visible applications does not necessarily correlate to a greater need as Bracknell is similar to other councils for rates of non-visible disabilities.

High application rates question whether applicants’ expectations were well managed. The Assistant Director recognised that the inclusion of non-visible disabilities was new for the public as well as for the council and agreed that providing clear and accessible information about eligibility was critical. The panel’s recommendations to improve the application form and provide enhanced local guidance should support clearer information.

Recommendation 1 - to capture the reasons for accepting an application - also supports good expectation management. It creates a knowledge bank, which not only supports fair decisions but will improve consistency. Consistent outcomes are key to managing the expectations of applicants. The details will also provide case studies, which can be used for training as well as external communications.

The panel interviewed Ollie Sirrell, a local democracy reporter who has written several articles on blue badge refusals in Bracknell Forest. He explained that his initial investigations into blue badge acceptance rates in Berkshire led to the BBC Freedom of Information request to 216 councils. Mr Sirrell has spoken to several families about their experience. He summarised that their dissatisfaction was caused by poor communication and not receiving a clear explanation why their application was refused.

The Assistant Director and the blue badge officer both recognised that good communication in all areas is critical to delivering an effective process. Their challenge is to communicate complex information in a way that supports a simple process.

The experience of residents

The panel heard from 5 residents covering a range of visible and non-visible disabilities, adult and child applicants and refused and accepted outcomes.

They noted the split that those who had received a blue badge were generally happy with the process and those who had been refused were not.

The panel recognised the impact that having a blue badge can have. One carer told the panel that being taken to the shops or on a trip out was the only outlet for their blue badge holder, giving him ‘a life outside the four walls’. Another parent said:

“It’s about making life as “normal” as possible – being able to go out, go to the shops and trying to integrate into a society that doesn’t always accept people who are a little bit different. That’s the kind of impact it can have on someone’s life.”

As a blue badge refusal reduces these opportunities, the panel were pleased to hear that refusal decisions are already subject to internal review before final letters are sent out. The panel recommends that this internal review confirms that the relevant psychological, medical or neurological evidence has been reviewed and understood, consulting experts as necessary. This change in focus recognises the increased range of conditions now considered.

Two residents described how their condition ‘fluctuates’, meaning there are times when they don’t experience much difficulty and other times when they have considerable difficulty walking or present a risk of serious harm to themselves or others. Both residents had been observed for a blue badge at what they considered to be ‘a good time’ and both were refused. They felt that this didn’t fairly represent their condition and that the application process didn’t allow them to represent their full experience. The panel recommends that the application process uses appropriate questions to reflect ‘fluctuating disabilities.’

Some conditions cross the visible and non-visible criteria. The panel heard from a resident who had been advised to apply under a non-visible disability, but their assessment appeared to be based on the visible criteria (which were relevant but didn’t represent the whole situation). The panel were concerned that making an application under a specific category may disadvantage those with complex needs which cross the criteria. The review recommends that the application form is revised to remove any barriers to a holistic assessment of an individual.

The panel recognised that creating a more inclusive form could make it very large as all potential questions need to be included. The review recommends creating an online form that will tailor later questions according to previous answers to make the process more manageable. An online process could also provide automatic updates, for example when evidence has been assessed, helping to keep applicants informed during an anxious time.

Online applications are not suitable for everyone and the panel noted that the application process must take account of all accessibility requirements, providing appropriate support and alternative methods where required. The panel suggests that Customer Services could be considered to provide initial support.

The panel highlighted that some approaches to data protection can create extra steps for process users. They recommend that data protection is integrated at an early stage to avoid introducing any barriers later in the process design.

Complex conditions often require a large amount of evidence and the assessment process can be extensive. The panel heard from a resident who had submitted a lot of evidence but found that the refusal letter didn’t provide satisfactory detail on the reasons for refusal. The letter made no reference to the evidence and how it had been reviewed so the applicant had little confidence it had been assessed. The review recommends that refusal letters are reviewed to make it clear the evidence has been assessed and understood, demonstrating greater empathy for the applicant and what a blue badge means for them.

The departmental review is prioritising actions needed for implementation of a new process (process design, team structure, training and so on). A review of letters would be a later activity, so this recommendation is made to the Executive for future work.

In support of this recommendation, one resident reminded the panel that the process should put the applicant at the forefront:

“It’s really important for the assessors to go out of their way to understand the situation that person is in.

“I think life for some people with disabilities will never be ‘normal’, but if there are things we can do as a society to support that I think we should always have that person at the forefront of what we’re doing.”

Evidence from a local support organisation

The Ark, a local organisation that supports people with disabilities and the disadvantaged, provided written evidence to the panel.

They advised that the process itself can be a barrier, particularly to those with non-visible or fluctuating disabilities. This insight supports the recommendations to improve the application form and provide clearer guidance with examples of evidence. Outreach work through local organisations will also help build understanding and reduce uncertainty.

The Ark explained that some conditions do not have ongoing medical or adult social care involvement, for example, autism in adults. However, the individuals often have extensive involvement with community and voluntary sector organisations (such as SIGNAL4Carers, PINC, Younger People with Dementia, Autism Berkshire, Age UK Berkshire). Expanding the range of people who can provide evidence for assessment purposes would make sure that these individuals can be more fairly represented.

Local authorities are responsible for the administration and enforcement of the blue badge scheme, and can implement administrative, assessment and enforcement procedures which they believe are in line with the governing legislation. The Ark highlighted this flexibility to shape policy locally. To take advantage of this, the review recommends that the approach in Bracknell Forest is clearly outlined in local guidance that shows how the council uses a number of tools (application form, website, wider range of evidence sources) to enhance the government approach.

"As Vice Chair of the Wellbeing and Finance Overview and Scrutiny Panel, I welcomed the opportunity to assist in the review of the blue badge process in view of the concerns shown by both applicants and their families and carers.

"I know personally of applications being rejected after having previously been issued with a blue badge. We heard directly from residents about the difference that having a blue badge makes, or would make, to their lives. Making fair decisions is key to people’s freedom and I am confident that, in future, any difficulties will be addressed in an appropriate manner."

Councillor Isabel Mattick, Vice Chair: Wellbeing and Finance Overview and Scrutiny Panel

"I would like to thank everyone who took part in this review: officers (from both Bracknell Forest and other councils), residents, local organisations and local media.

"I am particularly grateful to the residents who spoke to us about their experiences, both good and bad. Hearing first-hand about the impact of blue badges reinforced why this process is so important.

"The recent data might suggest that Bracknell Forest is performing in the lower quartile, and the ambition for this review is to move it to the upper quartile. Bracknell Forest is a caring council and we have taken on board everything we have heard. This has been an opportunity to reflect on our experience and look for any improvements for our residents."

Councillor Malcolm Tullett, Chair: Wellbeing and Finance Overview and Scrutiny Panel

Review panel

The review panel was made up of:

  • Councillor Alvin Finch
  • Councillor Isabel Mattick (Vice Chair)
  • Councillor Lizzy Gibson
  • Councillor Malcolm Tullett (Chair)
  • Councillor Mary Temperton
  • Councillor Michael Brossard
  • Councillor Mike Gibson
  • Councillor Nick Allen
  • Councillor Nigel Atkinson

Contributors to the review

Contributors and their role

Name

Role

Melanie O’Rourke

Assistant Director: Adult Social Care, Bracknell Forest Council

Gavin Austen

Assistant Community Services Manager - Occupational Therapy, Bracknell Forest Council

Ollie Sirrell

(Former) Local Democracy Reporter, Bracknell News

Blue badge applicants from Bracknell Forest

Andrea McCombie-Parker

Chief Executive, The Ark Trust

Sarah Piercey

Assessment Team Manager, Manchester City Council

Lauren Grosvenor

Blue Badge Team Manager, Lincolnshire County Council

Gordon Smith

Head of Blue Badge Service and Enforcement, Hampshire County Council

Angela Armstrong

Scrutiny and Legal Support Officer, Hartlepool Borough Council

Judy Trainer

Team Leader Scrutiny and Electoral, Stockton-on-Tees Borough Council

Earl Piggott-Smith

Scrutiny Officer, City of Wolverhampton Council

Jen Lawson

Governance and Scrutiny Officer for this review, Bracknell Forest Council

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