Disabled and older person’s travelcards

At least one appropriate document confirming the applicant’s identity should normally be provided. Acceptable evidence may include:

• Current or recently expired passport
• UK photocard driving licence
• Birth certificate
• Adoption certificate
• State Pension notification or entitlement letter
• NHS medical card or official NHS correspondence showing the applicant’s full name and date of birth
• DWP or other government-issued correspondence
• Immigration or Home Office documentation where appropriate
• Other official photographic identification accepted by the administering authority

Where the applicant’s current name differs from the name shown on the primary identification document, additional evidence may be required, for example:

• Marriage or civil partnership certificate
• Deed poll
• Change-of-name certificate
• Divorce documentation where relevant
• Other official documentation demonstrating the link between the two names

The applicant should demonstrate that their sole or principal residence is within the area of the Travel Concession Authority responsible for issuing the pass.

Evidence may include:

• Current Council Tax bill
• Council Tax benefit/reduction notification
• Utility bill
• Bank or building society statement
• Credit card statement
• DWP benefit or pension letter
• HMRC correspondence
• Local authority correspondence
• Tenancy agreement
• Mortgage statement
• Council or housing association rent statement or rent book
• Electoral registration evidence where available
• NHS correspondence
• Driving licence displaying the current address
• TV licence
• Residential care or nursing-home letter confirming residence
• Care-home invoice
• Letter from an authorised supported-living provider
• Marina/mooring documentation where this represents the applicant’s principal residence
• Caravan/site residential agreement where this represents the applicant’s principal residence
• Other official correspondence considered sufficient to establish ordinary residence

Where a document is being relied upon as current proof of residence, authorities may specify that it must have been issued within a defined period, currently the preceding three months across out Unitary Authorities.

Where an applicant has no conventional proof of address, the authority should consider reasonable alternative evidence, particularly for applicants who are homeless, residing in supported accommodation, living in residential care, or otherwise unable to provide standard household bills.

A recent passport-style photograph should normally be provided which:

• Is a clear and recognisable likeness of the applicant
• Shows the applicant’s full face
• Shows the head and shoulders
• Is in colour
• Has an uncluttered/plain background where practicable
• Is sufficiently clear for the passholder to be identified when travelling
• Does not normally include sunglasses or face coverings that prevent identification
• Permits religious or medically necessary head coverings provided the face remains sufficiently visible

The issuing authority may take the photograph directly where applications are made in person.

An applicant must establish that they have reached the applicable statutory qualifying age.

Evidence of age may include:

• Passport
• Birth certificate
• Adoption certificate
• Photocard driving licence
• State Pension award/entitlement letter
• Pension documentation showing date of birth
• NHS documentation showing date of birth
• Other official documentation which reliably establishes the applicant’s date of birth

The authority should establish eligibility against the State Pension age applicable to the applicant, rather than applying a locally selected age threshold.

In addition to evidence of identity and residence, the applicant must demonstrate that they fall within at least one of the seven statutory disability categories.

Evidence should relate directly to the qualifying criterion rather than merely demonstrating that the applicant has a medical diagnosis.

Where appropriate, evidence may include:

• DWP benefit award documentation
• Specialist medical reports
• Consultant letters
• Hospital reports
• Reports from suitably qualified healthcare professionals
• Audiology reports
• Ophthalmology/optometry evidence
• Certificate of Vision Impairment
• Local authority disability registration
• Adult social care records or confirmation
• Learning disability service records
• Education, Health and Care Plan evidence where relevant
• DVLA correspondence
• Independent mobility assessments
• Occupational therapy assessments
• Physiotherapy assessments
• Other independent professional evidence directly addressing the statutory eligibility criterion

A GP letter should not routinely be the first or only form of evidence requested where better evidence is available. Where medical input is required, DfT guidance recommends that independent medical evidence be used where practicable and that any questions put to a GP should seek factual information rather than asking the GP to decide whether the statutory ENCTS test has been met.

Personal Independence Payment – Moving Around

Evidence:

• Current PIP award letter showing an award of at least 8 points for the “Moving Around” activity

The award should normally demonstrate that the entitlement has been awarded for, or is expected to continue for, at least 12 months.

Personal Independence Payment – Communicating

Evidence:

• Current PIP award letter showing an award of at least 8 points for the “Communicating Verbally” activity

Disability Living Allowance – Higher Rate Mobility Component

Evidence:

• DLA award letter confirming receipt of the Higher Rate Mobility Component
• Most recent DLA uprating letter where necessary to demonstrate that the award remains current

War Pensioner’s Mobility Supplement

Evidence:

• Current award letter or equivalent official documentation confirming receipt of the War Pensioner’s Mobility Supplement

Receipt of other benefits may provide useful supporting evidence, but does not in itself establish automatic statutory ENCTS eligibility unless the evidence demonstrates that one of the qualifying statutory criteria is satisfied.

A Blue Badge should similarly not automatically be treated as establishing ENCTS eligibility, because the Blue Badge and ENCTS eligibility tests are different.

Suitable evidence may include:

• Certificate of Vision Impairment (CVI)
• Confirmation that the applicant is registered as:
  • Severely Sight Impaired (Blind); or
  • Sight Impaired (Partially Sighted)
• Ophthalmologist report
• Optometrist report
• Other specialist eye-health evidence establishing that the applicant would meet the criteria for registration

Registration itself is not compulsory. An applicant who is not registered should not therefore be rejected solely because they are absent from the local authority register.

The relevant issue is whether the level of sight impairment is sufficient for the person to qualify for registration as severely sight impaired or sight impaired.

Suitable evidence may include:

• Audiology report
• Audiogram
• ENT/aural specialist report
• Consultant audiologist evidence
• Confirmation of relevant registration with local authority/social care services, provided the degree of hearing loss is also established
• Other specialist evidence confirming severe or profound hearing loss

DfT guidance generally identifies:

• Severe hearing loss: approximately 70–95 dB HL
• Profound hearing loss: approximately 95+ dB HL

The evidence should therefore establish the degree of hearing loss rather than merely confirming that the applicant uses hearing aids or has some hearing impairment.

Suitable evidence may include:

• PIP award letter showing at least 8 points under “Communicating Verbally”
• Speech and language therapist report
• Consultant or specialist medical evidence
• Relevant neurological evidence
• Other professional evidence demonstrating that the applicant is unable to communicate orally in any language

Evidence should demonstrate that the applicant is unable to make basic oral requests or ask questions verbally.

Difficulty speaking, slow speech, a speech impediment or severe stammer would not, by itself, normally satisfy this statutory category where the person remains able to communicate orally.

Evidence should demonstrate both:

• A substantial adverse effect on walking ability; and
• That the impairment is long-term.

Suitable evidence may include:

• PIP award showing at least 8 points for “Moving Around”
• Higher Rate Mobility Component of DLA
• Consultant report
• Physiotherapy report
• Occupational therapy assessment
• Specialist mobility assessment
• Hospital or rehabilitation evidence
• Independent medical assessment
• Relevant evidence concerning walking distance, speed, pain, breathlessness, balance, gait or the physical effort required to walk
• Evidence relating to serious deterioration in health caused directly by the physical effort of walking

The assessment should consider the functional effect of the impairment, including factors such as:

• Distance the applicant can reasonably walk
• Speed
• Length and frequency of rests
• Degree of pain
• Excessive fatigue
• Breathlessness
• Manner of walking
• Balance
• Risk to health
• Use and effect of mobility aids
• Whether the walking difficulty is long-term

The presence or absence of a wheelchair, walking stick, crutches, prosthesis or other aid should not determine eligibility by itself.

DfT advises that authorities should normally require medical evidence where eligibility depends upon substantial and long-term impairment of walking.

Suitable evidence may include:

• Consultant report
• Hospital or specialist medical evidence
• Occupational therapy assessment
• Rehabilitation documentation
• Evidence of bilateral upper-limb amputation
• Evidence of limb-reduction deficiency
• Evidence establishing long-term functional loss of both arms
• Other independent medical evidence demonstrating inability to use both arms for ordinary day-to-day activities

Where the disability is not immediately evident from the nature of the impairment, independent medical evidence should normally establish the extent and duration of loss of function.

The test encompasses not only absence of both arms but also circumstances where both arms are present but cannot be used for normal day-to-day activities.

Evidence should demonstrate a qualifying learning disability involving:

• Arrested or incomplete development of mind;
• Significant impairment of intelligence; and
• Significant impairment of social functioning.

The disability must have originated before adulthood and have a lasting effect on development.

Suitable evidence may include:

• Confirmation from Adult Social Care/Learning Disability Services
• Local authority learning disability register
• Consultant psychiatrist or psychologist evidence
• Learning disability specialist evidence
• Education, Health and Care Plan
• Historic Statement of Special Educational Needs where relevant
• Evidence of specialist educational provision
• Social care assessment
• Evidence from a recognised learning disability service
• Independent medical or psychological assessment

A learning difficulty, such as dyslexia, would not automatically establish eligibility unless the statutory learning-disability test is met.

Where the applicant has had no previous contact with specialist services, DfT advises that the authority should normally seek independent medical advice or check any relevant learning disability register.

• Psychiatry/specialist mental-health evidence where applicable
• Ophthalmology evidence
• Diabetes specialist evidence
• Other independent medical evidence demonstrating that the applicant would be unable to satisfy DVLA Group 1 medical standards

Potential conditions may include, depending upon their severity and circumstances:

• Epilepsy
• Certain seizure disorders
• Conditions causing sudden attacks of fainting or giddiness
• Certain severe mental disorders
• Significant visual-field impairment
• Failure to meet the statutory eyesight standard
• Certain neurological conditions
• Certain cardiac conditions
• Certain locomotor conditions
• Certain renal conditions
• Diabetes involving disabling hypoglycaemia
• Other conditions which would make driving a danger to the public

Eligibility must be determined against the applicable DVLA medical-fitness standard, rather than merely because an applicant has one of these diagnoses.

Persistent misuse of drugs or alcohol is specifically excluded from this statutory ENCTS category.

Where the qualifying disability may change, the evidence should establish:

• The expected duration of the condition;
• Whether it has lasted, or is expected to last, at least 12 months where relevant;
• Any review date associated with a qualifying benefit;
• Any expected recovery or reassessment date.

The authority may align the expiry of the ENCTS pass with an appropriate review date, including the expiry of a qualifying PIP award, where justified.

For permanent conditions, repeated requests for new medical evidence at every renewal should normally be avoided unless there is a legitimate reason to reconsider eligibility.

Companion travel is a local discretionary enhancement, rather than part of the national statutory ENCTS entitlement. The authority should therefore specify separately the evidence required to demonstrate that the passholder cannot reasonably use public transport without another person’s assistance.

Suitable evidence may include:

• Social care assessment demonstrating a need for support when travelling
• Occupational therapy assessment
• Mobility assessment
• Medical or specialist evidence explaining why assistance is required
• Evidence of severe cognitive or learning impairment affecting independent travel
• Evidence of substantial sight impairment requiring assistance
• Evidence that the applicant requires physical assistance to board, alight or travel safely
• Evidence of significant behavioural, communication or orientation difficulties which prevent independent travel
• Existing care/support plan
• Relevant Personal Budget or care-package documentation
• Education, Health and Care Plan where relevant
• Confirmation from an appropriate professional with direct knowledge of the applicant’s support needs

The assessment should focus on the applicant’s functional need for a companion when travelling, rather than diagnosis alone.

In the West of England, companion travel is provided as a locally funded enhancement for eligible disabled or older passengers requiring assistance and sits in addition to the statutory ENCTS entitlement.

Where the authority distinguishes companion passes or local enhancements according to wheelchair use, evidence may include:

• Occupational therapy evidence
• Wheelchair service documentation
• NHS wheelchair-service letter
• Mobility assessment
• Relevant medical evidence
• Evidence confirming routine dependence on a wheelchair for mobility

Evidence should only be requested where the endorsement affects the entitlement or administration of the local scheme.

For renewal, evidence requirements should be proportionate to whether eligibility is likely to have changed.

The authority may require:

• Confirmation that the applicant remains resident within the authority area
• Updated photograph where the existing photograph no longer provides a reliable likeness
• Current disability evidence where the qualifying condition was temporary or subject to review
• Current PIP/DLA/WPMS documentation where the previous award had an expiry/review date
• Updated medical evidence where eligibility depended on a condition which may have materially changed
• Confirmation of any change of name or address

Fresh medical evidence should not normally be required solely as an administrative exercise where the authority already holds reliable evidence that the qualifying condition is permanent.

For lost, stolen, damaged or defective passes, the authority may request:

• Applicant’s full name
• Date of birth
• Current address
• Existing pass number, where known
• Confirmation of the circumstances of loss, theft or damage
• Updated photograph where necessary
• Proof of identity where there is doubt as to the applicant’s identity
• Evidence of change of address or name where relevant

The underlying statutory eligibility would not ordinarily need to be reassessed solely because a pass has been lost or damaged. There is currently a £10 charge for pass replacement.

Evidence may include:

• Council Tax bill
• Utility bill
• Bank statement
• Tenancy agreement
• Government correspondence
• Other acceptable proof of the new principal residence

Where an applicant has moved outside the issuing TCA’s area, they should normally apply to the TCA responsible for their new principal residence.

Evidence may include:

• Marriage certificate
• Civil partnership certificate
• Deed poll
• Statutory declaration
• Gender Recognition Certificate where the applicant chooses to use it
• Updated passport or driving licence
• Other official evidence linking the previous and current identities

Only information necessary to establish the applicant’s identity and maintain an accurate pass record should be requested.

Where someone applies on the applicant’s behalf, evidence may additionally be required to establish their authority to act.

This might include:

• DWP appointeeship
• Lasting Power of Attorney
• Deputyship order
• Parental responsibility for a child
• Appropriate guardianship documentation
• Applicant’s written authority
• Other legally recognised authority to act

The ENCTS eligibility evidence should nevertheless relate to the passholder rather than the representative.

Where reasonable concerns arise over the authenticity or accuracy of evidence, the authority may undertake proportionate verification, including:

• Checking documents against authority records
• Verifying residency
• Confirming qualifying benefits where lawful
• Confirming details with DWP in appropriate circumstances
• Confirming information with relevant medical professionals where consent and an appropriate lawful basis exist
• Checking Adult Social Care records where legally permissible
• Checking whether another valid ENCTS pass has already been issued
• Checking previous or duplicate applications
• Requesting original or higher-quality copies where submitted evidence is illegible or appears altered

DfT specifically recognises that where the authenticity of a PIP award letter is uncertain, appropriate checks may be undertaken, exceptionally including verification with DWP.

Unless it independently demonstrates the relevant statutory criterion, the following should not automatically establish entitlement:

• Blue Badge
• General statement that the applicant is “disabled”
• Diagnosis alone
• Attendance Allowance
• Standard-rate mobility benefit without evidence satisfying an ENCTS criterion
• Employment and Support Allowance
• Universal Credit
• Carer’s Allowance
• Armed Forces compensation other than a qualifying mobility award
• Use of a wheelchair or walking aid by itself
• GP registration
• Prescription medication
• Informal statements from friends or family
• Previous receipt of an ENCTS pass from another authority without confirmation of the basis of eligibility

These may nevertheless form part of the overall evidence where relevant.

When determining whether evidence is sufficient, the authority should ensure that:

• Decisions are based on the statutory ENCTS eligibility criteria.
• The applicant is given a reasonable opportunity to demonstrate eligibility.
• Evidence requirements are proportionate.
• Diagnosis is distinguished from functional eligibility.
• Independent specialist evidence is preferred where specialist assessment is required.
• Applicants are not unnecessarily required to obtain paid-for GP letters where suitable existing evidence is available.
• Permanent disabilities are not repeatedly reassessed without justification.
• Temporary conditions are distinguished from qualifying long-term disabilities.
• Similar cases are treated consistently.
• Reasonable adjustments are made for disabled applicants.
• Alternative evidence routes are available where conventional documentation cannot reasonably be obtained.
• Only information necessary for determining eligibility and administering the scheme is collected.
• The authority records which statutory disability category has been relied upon and the basis on which eligibility was established.
• Where an application is rejected, the applicant is told why and advised of the authority’s complaints/review procedure.

DfT specifically recommends that authorities record the disability category under which an applicant qualifies, together with how and by whom the assessment was undertaken.