Equalities Discrimination v People with Mental Health Issues who require bus passes in Greater Manchester

Manchester Users Network are campaigning for Transport for Greater Manchester to reduce the length time it takes for service users of mental health services to access their bus passes. There are a lot of service users with severe and enduring mental illness in this situation. MUN are demanding that TfGM should make extension or pay compensation if they end up with no pass when delays are TfGM’s fault. 

They are also dissatisfied with the application form as it disregards current statuary guidance froml 2013.

The ways assessment are conducted for determining legibility for a pass have now been changed by TfGM with Occupational therapists doing most of the assessments. This information should be included in the form, as is stated in the guidance. Further, CPNs, Social Workers and Occupational Therapists are all regarded as qualified Mental Health Professionals within the Mental Health Teams who can carry out assessments.      

We have written to TfGM requesting immediate action to address this (see below)

We also include a letter of support for MUN’s campaign from the National Survivor Users Network (also below):

Dear Cllr Aldred, Chair of TfGM
FOA of Mr Dybell, Transport For Greater Manchester

Re. Equalities Discrimination v People with Mental Health Issues who require bus passes

I am writing to you on behalf of CHARM, a Manchester based Mental Health campaigning organisation made up of service users, family members and workers.

We have been informed by the Manchester Users Network that many mental health service users living in the community and in-patients with severe & enduring mental health issues are having serious problems receiving Bus Passes from Transport for Greater Manchester.
This is seriously effecting service users across the 10 local authorities of Greater Manchester.  

We have been informed that TfGM is not implementing important parts of National guidance for England of the ENCTS (National Concessionary Travel Scheme) last updated 2013. 

We regard this as a serious injustice that is causing many people severe stress and anxiety because of the delays in renewing bus passes arising from an overly bureaucratic system.

The delay means that people previously entitled to Bus Passes are now having to pay to use Public Transport whilst they wait for there new bus pass to arrive  thereby causing barriers to attending  appointments, treatments and therapies and also slowing discharge from hospitals. 

There are also serious financial consequences. We have been told by the MUG that one service user has been waiting since October 2021 for a renewal his pass. Whilst another paid £35 to his GP to fill in the form, and has heard nothing from TfGM since, This has impeded his capacity to attend appointments and therapies before 09.30am. Being aware he would become ill if this occurred and unable to take the pressure, he decided to accept an Older Persons bus pass, which he cannot use before 09.30am, also ending up paying another £10 to use the tram and local trains. 

We understand that TfGM is not offering financial compensation for people effected by these delays in renewal of bus passes which we understand has caused hardship for those effected.

Issues that require your urgent attention include:

  • Most service users have their requirement for a bus pass assessed by their Community Psychiatric Nurse or Psychiatrist from their Mental Health Service this is then forwarded to TfGM, there are then significant delays in bus passes being issued. We believe this is due to the volume of bus pass assessment that need to carried out as the length of time that a bus pass is valid has been reduced to 2 years up to a maximum of 3 years from the previous practice that was up to 5 years.
  • The forms are over bureaucratic, ask unnecessary and irrelevant questions, for example requiring information about prescriptions of medication. This places applicants under further duress, as if you do not take psychotropic medication, you appear to be not entitled to a Bus Pass. This is not the case as people may have talking therapies or conditions for which medication is not prescribed.

To summarise, the crisis is partly due to shorter awards, the vast majority of passes awarded for just for 2 years this is causing a bottleneck, further the amount of bureaucracy within the TfGM renewal application process and one year awards during Covid, further issues of concern and poor communication and requiring unnecessary with information.  

We advise you to research best practice across the country (for instance our neighbours  Lancashire) and to liaise with service user groups in revising and improving the system so the process meets the requirements of  the Equalities Act.  

We expect a response as soon as possible to the concerns expressed above. We will keep this situation under review and if necessary will be contacting the media to give this issue more public attention.

Yours sincerely

Paul Baker


See also letter on behalf of the Manchester User Network (MUN) from the National Survivor User Network:

National Survivor User Network
Kemp House
152-160 City Road

25th May 2022

To the Chief Executive, TfGM/ GMCA, Eamonn Boylan

I am writing on behalf of the National Survivor User Network, an England-wide network of people living with mental ill health and/or distress to express our concerns regarding ongoing delays and challenges in accessing concessionary bus passes for disabled people in Greater Manchester.

Manchester User Network (MUN) has brought this situation to our attention and we would urge you to act quickly to address the concerns raised by MUN, CHARM, and others in Greater Manchester.

We are particularly concerned of reports of:
1 year bus passes being issued over the Covid period and the overall reduction of the maximum time period from 5 years to 3 years
Delays in renewals leaving eligible people without access to transport
Reliance on costly GP letters as evidence without reimbursement
Requesting prescriptions as evidence for eligibility

The Department for Transport’s guidance to local authorities on assessing eligibility for concessionary bus travel explicitly states in points 23, 24, 25, 26 and 29, the conditions of medical assessment. These include avoiding relying on GPs so as not to compromise doctor-patient relationships (24), seeking independent assessment in uncertain cases without individuals bearing the cost (23), running assessment centres (26) and recognising the importance of independent health professionals including occupational therapists (25). Reliance on GPs is described as a ‘last resort’ where GPs should only be asked “for answers to factual questions. They should not be asked for an opinion on whether someone meets the criteria.” (29).

We therefore share the concerns that these guidelines are not being followed, to the detriment of those in Manchester eligible for concessionary travel on the basis of disability and health conditions.

In addition to this, requesting prescriptions as evidence of eligibility can be read as a coercive request with the implication that choosing not to take a prescribed medication may mean the difference between being able to move around your town, access appointments and vital social support or not.

As I am sure you are aware, mobility is of critical importance to people living with long term mental ill health or distress. It can alleviate social isolation and facilitate access to healthcare and support structures in the community such as peer support groups. In the context of the current cost of living crisis, it is especially crucial that further pressures are not placed on Greater Manchester residents who are eligible for passes because of disability.

Many who live with long term mental ill health or distress may also have long term physical health conditions. Ensuring that individuals who have dual or multiple diagnoses are not excluded from concessionary travel is critical.

Bureaucracy can be a significant barrier to accessibility, and may mean that many who are eligible for and would benefit from a pass do not have access. Simplifying the process and issuing longer term passes is a step forward in facilitating access.

We urge you to liaise with service user groups in Greater Manchester and to establish an understanding of best practice nationally to improve the situation for all those eligible for disabled persons freedom passes in Greater Manchester.

In addition, examining practice in Greater Manchester and assessing areas where it does not meet the standards set out by the Department for Transport’s guidance

We hope to hear from you regarding this situation in due course.

Yours sincerely,

Mary Sadid

Policy Officer, National Survivor User Network

Published by CHARM Greater Manchester

CHARM, the Community for Holistic, Accessible, Rights Based Mental Health was launched by The Organic Recovery Learning Community in September 2020.

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