Pre-Budget Submission 2006
Release Date: Dec 13th, 2006
Introduction:
Most of the recommendations made here are reiterations of arguments made in submissions to previous budgets. That they are made again, is self evident that they have gone unaddressed in previous budgets. It is a request of Government that in this year, the 75th anniversary of the founding of NCBI, that a special effort is made to respond positively to some, if not all of the recommendations contained in this submission to improve the lives of people experiencing significant sight loss and blindness.
Over 10,000 people in Ireland today on NCBI’s service database are officially classified as “blind”. To be classified with a significant sight loss is psychologically difficult for people to face. Many people put off for years asking for help with the problems caused by reduced vision. Using patterns of sight loss in countries of similar size to Ireland, NCBI forecasts that a staggering further 48,000 people in Ireland may experience sight loss, with a quality of life reduced significantly by not being able to admit to sight loss.
As people live longer and grow older, their sight will weaken and ultimately diminish. NCBI represents the interests not only of the 10,000 people with whom it works, but is also concerned for the welfare and well being of the many who are not currently availing of any services at all. NCBI must also have regard for those people with low vision who are likely to require support services over the coming years, arising from factors of lifestyle and ageing conditions. It is known that habitual smoking is linked to macular degeneration and that obesity may lead to diabetes and consequential damage to sight.
NCBI is impatient to see service improvements made in the arrangements for funding services offered to vision impaired people, and also in those statutory payment schemes upon which vision-impaired people rely to sustain themselves. The schemes are identified in this pre-budget submission and recommendations are made for improvements.
Blind and partially sighted people and their health-funded services, are perceived by the vision impaired sector as being low in funding priorities relative to other disability categories. There is often a disconnect between the espoused language of inclusion and the actual practice of prematurely shepherding people into forms of provisions which sometimes isolate people from and within their own communities. NCBI says that there is sometimes an over-emphasis in the creation of programme and design of schemes which favour centre-based provisions, including residential care and these work against the NCBI ethos and that of our sister blindness organisations and our forms of service deliveries of sustaining people in their own communities and their own homes.
NCBI is particularly concerned that government should pay particular attention to ensuring that people with significant sight loss in their older years gain access to services which would have been available to them were they to be under the age of sixty-five years. Compartmentalising funding streams by programmes is leading to inequities, which will only worsen in time if not addressed in the early years of the new HSE. Older people with vision impairments should be entitled to an increase of service provision and not, as might happen, a reduction in them.
The nine recommendations in this submission are framed around submissions NCBI has been making in the course of our last pre-budget submissions. We trust that our strategy of repeating and reminding Government will ultimately bring recognition for the arguments we present for improvements in core statutory provisions. NCBI also argues for funds to be released from the capital programme to meet the cost of improving the service provisions which are provided out of NCBI’s property at Whitworth Road, and which is in urgent need of refurbishment. Modernising these premises will ensure that as NCBI celebrates 75 years of service to vision impaired people, resources are being put in place to guarantee quality services into the future.
1. Changes in VAT:
A. Talking Books and E-books:
In Ireland, VAT is levied at zero per cent on print books. Books, newspapers and periodicals are eligible for a reduced rate of VAT under EU rules (provided for in Annex H), and most other member states apply a reduced rate of around 5%.
Audio books and e-books, on the other hand, are not eligible for any reduced or zero rates, and carry the full rate applicable in each member state.
NCBI calls on the Minister for Finance to exercise his rights of derogation to introduce a zero rate of VAT on all talking books in tape and disk forms and on E-books purchased through the Internet. We recommend that the eligibility of what constitutes a book should be determined by reference to an article in print on which the zero rate of VAT is applicable.
European blindness organisations, the Spoken Word Publishing Association and the Society of Authors have all, at different times, expressed the view that all books, whatever their format, should benefit from the same rate as print books. From the point of view of “A Right to Read” for blind and vision impaired people, this would mean that all books were treated equally and that the discrimination in the VAT regime against formats which blind, vision impaired and other print disabled people are obliged to use would end. It would also encourage a larger commercial market in these formats, thus reducing the gap between print publications and the proportion available in accessible formats.
B. Extension of Zero rated disability aids:
Technology of all sorts and adaptive software is playing an ever-increasing role in improving the inclusion of people who are blind and vision impaired into the learning, working, cultural and recreational life of the community. Some of these items can be prohibitively expensive for the average individual to purchase. NCBI recognises that a VAT refund scheme exists whereby VAT may be refunded to a purchaser of equipment bought to overcome the handicapping aspects of a disability, and that this scheme has much merit. Nevertheless, the scheme requires that the VAT be paid in order for it to be refunded, necessitating initial unnecessary outlay on the eligible aid by the equally eligible individual.
NCBI recommends that the refund scheme be retained but that the following three items commence a list of articles on which a zero rate of VAT applies. These three items are identified because they have a cost of in excess of €2,000. NCBI wishes the “three item list” to be the basis for further additions by means of negotiation with officials of the Department of Finance:
- Braille printers and devices for embossing Braille or providing tactile reading by means of mechanical pins.
- Devices and/or software which enable the scanning of printed texts into a digital form for immediate conversion to either Braille or speech.
- Devices known as CCTVs (close-circuit televisions) which are specifically manufactured to allow people with low vision to magnify books and documents on to a TV screen or computer monitor.
Cost of provision:
VAT on Talking and E-books: NCBI does not have available data to indicate the cost of this provision which should be viewed as a matter of social equity and should not be costly on government.
VAT on disability aids: There would be no cost to government in meeting this provision as it already meets the cost of the provision by means of “refund”. This should be viewed as a matter of social equity.
2. Blind Persons Pension
NCBI recommends that steps be taken towards responding to the higher than average living costs of people with disabilities and of blind persons’ in particular by paying the Blind Persons’ Pension regardless of means. Non means-tested disabled persons’ pensions are paid in many EU member states. It is recommended that this be phased in over a period not exceeding five years from the first year of commencement. The phased implementation of this recommendation should be commenced in the next budget by disregarding as reckonable means at least 20% of the Blind Persons’ Pension, expanding the disregarded means in subsequent budgets until the total pension is payable without reference to means.
NCBI considers that five years should be set as the time-scale for phasing out the means test on the blind persons’ pension. This recommendation is in keeping with research carried out by the NDA which supports a “Costs of Disability” scheme. Adjustments to the Blind Persons Pension could be regarded as being the beginning of such an arrangement, to be extended in subsequent budgets to other persons with disabilities.
Cost of provision:
NCBI calculates that the cost of meeting this recommendation in year one will be €1.65 million before the payment of income tax on aggregated incomes. The cost of meeting the provision, in full, over five years will be approximately €8.25 million with nearly half of this sum being returned to the Exchequer through the payment of income tax and the phased abolition of the Blind Persons’ Tax credits.
3. Disability Benefit and Blindness
Where an employed person ceases working because of substantial deterioration in their eyesight and where they become eligible to receive disability benefit as a result, NCBI recommends that the disability should be treated similar to an occupational injury. The resultant gain for the individual should be that he or she becomes eligible to receive an occupational injury pension until age 65 regardless of whether or not they were subsequently employed. Only where the person is unemployed would they receive both Occupational Injury Pension and Blind Pension. Where the person entered employment, the Blind Persons’ Pension would cease to be paid.
Cost of provision:
The cost of meeting this provision is calculated as being less than half a million in a full year. This half a million euro is already provided for in the provision for disregarding means on the Blind Persons’ Pension generally but should, in this instance, stand alone as an immediate recognition of the needs of a small number of persons who go blind during their working lives and who could return to work with the removal of a perceived disincentive to work.
4. Blind Persons Tax Credits (BPTC)
The changes in the last budget changed the Blind Person’s tax credit from €1,000 to €1,500 for a single person and from €2,000 to €3,000 for a married couple. NCBI recommends that the tax credits should be increased in this budget to €2,000 for a single person and €4,000 for a married couple.
It is recognised in making this recommendation that the linkage of non means-tested Blind Persons’ Pension and the Blind Persons’ Tax credits will see a switch from the negative income of the BPTC to the direct payment of a Blind Persons’ Pension that will be subject to payment of income tax. As the Blind Persons’ Pension becomes eligible for payment in percentages that disregard means, the credits for blind persons would be phased out accordingly.
Cost of provision:
The cost of this provision can be translated into the non means-tested arrangements outlined earlier (no. 2) in this submission. NCBI recommends the increase at the level sought to facilitate the funding of the non means-tested arrangement in years one and two.
5. Broadening of Means-test:
The scale of means to be disregarded when calculating eligibility for a blind persons pension has moved slowly over the years in terms of capital, saving and other disposable income which can be held by an otherwise eligible individual.
NCBI asks the Minister for Community and Family Affairs to pay particular regard to this lack of movement and to address it in some way in the upcoming budget.
Cost of provision:
There is no cost of provision as the cost is determined only with reference to the percentage in the movement of “disregarded means”.
6. Blind Welfare Allowance (BWA)
Steps should be taken to implement the transfer of responsibility for BWA from the HSE to the Department of Social and Family Affairs. The transfer should be used to create a new, increased, Blind Persons Pension. When the allowance was first paid in 1953, it was in recognition by the then Minister for Finance (James Ryan) of a 25% higher income requirement by blind persons’ over recipients of the old age non-contributory pension to which the blind persons’ pension was linked.
Cost of provision:
There will be no extra costs to the Government in making the changes as suggested here. Indeed, there may be a saving from the rationalising of payment mechanisms and combining them with the more cost efficient procedures developed by the Department of Social and Family Affairs.
7. Telecommunications
NCBI also recommends that telecommunication charges be subsidised for blind and vision impaired persons and that the allowance for the use of the mobile telephone be further increased in this budget. The cost of broadband rentals should also be met for blind subscribers.
The recommendations made here are made in the light of the telephone and the computer playing an important part in the lives of people who are blind. For some, the phone is their only means of daily contact with friends and family.
Cost of provision:
It is difficult to estimate the full cost of this concession in a full year as rental and unit charges vary from operator to operator. NCBI recommends that government allocate €1 million to these improvements in this budget.
8. Car and Mobility allowance
NCBI has been drawing attention over many pre-budget submissions to the importance of the car to the independence of blind persons, particularly in rural Ireland. Free travel concessions are generally available to all blind persons but this concession is useless where no public transport service exists. The family car is not alone the most flexible means of travel but the only means of transport in many areas of rural Ireland.
A. NCBI recommends that 50% of the Mobility Allowance be initially extended to blind persons (free of means test) between the ages of 18 and 65 years to allow them avail of private transport services such as taxis and hackney cars. Even with the concession of free travel on public transport, many vision-impaired persons find that they have to meet the considerable cost of private transport in the course of living their social and working lives.
B. NCBI further requests that a vision-impaired person in receipt of Mobility Allowance who opts for the disabled drivers/passengers grant be permitted to convert the value of five years Mobility Allowance into the disabled passengers car grant. The Mobility Allowance would then cease to be paid for a period of five years to the individual opting for the car grant.
Cost of provision:
We would estimate that no more than 200 people would avail of the converted mobility allowance to car grant at a cost of no more than €1 million over five years. The Mobility Allowance extension to vision-impaired people under the age of 65 years and over the age of 18 years at 50% of normal means tested rate would be approximately €600,000.
9. Special Communications
The provisions of “The Disability Act” now guarantee communications in accessible formats. In order to accelerate the means to give effect to this aspiration, NCBI requests a one-off grant of €500,000 to purchase printers and recording equipment. The equipment to be used in support of Government as it meets its obligations under the relevant sections of the act and sectoral plans.
Cost of provision:
A once-off grant of €500,000 would enable the NCBI to meet its desired objectives in special communications.
10. Special Capital Grant:
The NCBI main Dublin and national facility at Whitworth Road in Dublin is now, in a building sense, coming to the end of its useful life. Most of the property was built in 1818 and partially refurbished by NCBI in 1987. As NCBI moves into planning service delivery beyond this, our 75th anniversary year in 2006, to sustaining a service future to people who are blind and vision impaired, we must re-organise ourselves to work out of a key service facility which is physically accessible and will meet the challenges of flexible service deliveries into the future.
The re-build of the existing premises will result in the provision of an extra 10,000 square feet to be added to a similar square feet in a refurbished 180 year old building - providing custom built accommodation for new low vision clinics and service areas for rehabilitation and technology services. The capital cost of the development is approximately €5.2 million. NCBI can contribute upwards of €1.2 million towards this cost but requests consideration for a grant of €4 million.
Cost of provision:
€4 million as a one-off grant. No additional revenue costs would flow from this provision.