Research and analysis

Markets that work well for disabled people

Updated 13 November 2018

On 16 October 2018, the Competition and Markets Authority (CMA) hosted a roundtable discussion with Scope. The roundtable focused on the challenges experienced by disabled people when navigating markets and the potential solutions to these challenges.

The roundtable comprised presentations from the CMA, Scope, an interview with a parent about his lived experience of caring for a child with multiple disabilities and plenary discussions.

Representatives of Government departments, regulators, consumer groups, charities, and business representative organisations attended. The roundtable was held under Chatham House rules.

The remainder of this summary sets out key points from the presentations and some of the issues raised by attendees during plenary discussions.

Understanding the challenges

Speaker Presentations

The CMA introduced the roundtable outlining its overall programme of work on consumer vulnerability and recent relevant projects, including its care homes market study and accompanying consumer enforcement. It also highlighted a market study that the CMA’s predecessor, the Office of Fair Trading, had carried out on mobility aids, which found that disabled people were more likely to be vulnerable when making purchasing decisions, due to a range of factors including their limited mobility and age-related conditions.

Scope presented findings from research on the Disability Price Tag which estimates that disabled consumers face average additional costs of around £570 per month. It suggested there was a combination of causes including low competition in the market for specialist equipment; poor accessibility (both digitally and physically); and poor customer service, meaning that disabled people are less likely to shop around.

Scope noted problems associated with the use of the term ‘vulnerable’ to describe disabled consumers. While some disabled people would define themselves as vulnerable, research carried out by Scope has found that over half do not. If services are targeted at vulnerable people, then they might be ignored by those disabled people who do not define themselves as vulnerable.

Scope interviewed a parent about his lived experience of the extra costs of caring for a child with multiple disabilities. The parent highlighted how extra costs can be experienced across a range of goods and services – including costs associated with: regular parking for hospital appointments; buying specially adapted clothing, higher energy usage and transport-related costs such as hiring wheelchair-friendly taxis. Difficulties were also reported in accessing common gateway products, such as insurance for holiday travel.

Financial challenges were also experienced arising from the relatively frequent purchase of bespoke wheelchair equipment (every 3 or so years). The tailor-made nature of such equipment means that companies are not willing to buy them back once they have been outgrown. It was suggested that introducing a part-exchange scheme would both reduce waste and lower the cost of new wheelchairs.

Day to day priority caring activities take time and energy, as well as placing a strain on finances. Such stresses can in turn have an impact on mental health and wellbeing. Such pressures often result in the carer having less time and ‘headspace’ to engage and deal with specific markets when problems occur.

Plenary discussion

Participants raised the following issues when discussing the challenges:

Whilst the UK population has increasingly gone online to buy insurance products, the mass market may not be the best solution for meeting the needs of some disabled groups. In particular, concerns were raised about:

• accessibility issues that prevented disabled people from getting the right deals;
• the suitability of both the quotes being given and the difficulty of finding specialist services;
• whether the lack of critical mass for some disabilities disincentivises the industry to respond;
• how the lack of transparency in the metrics used and how prices are determined makes it difficult to assess whether disabled people are receiving fair deals.

It was suggested that better signposting to specialist underwriting services for some disabled groups should be part of the solution for improving outcomes. The RIDC and Which? provide free information on insurance companies that offer specialist services and tailor quotes to the needs of disabled people.

Problems can also occur when inadequate information is shared when disabled customers switch providers (for eg when using third party intermediary websites or when switching is organised by friends/family). Disabled people may subsequently find out that details about their condition have not been shared with their new provider until they are in need of extra support.

Businesses should make better use of data and engage if there are apparent changes in customer behaviour. For example, if someone with dementia misses several mortgage payments after years of paying on time, the financial service provider should proactively check-in with that customer and/or their carer.

The difficulty of remembering PIN numbers can be an issue for people with dementia. Bank branch closures have also led to the reduction of face to face support being available for customers with dementia, as well as other disabled groups.

There are challenges for businesses in understanding both the common approaches to vulnerability that can be implemented across the piece, and the more specific needs of particular priority groups. There are also challenges in providing the right level of training for frontline staff as it is difficult to know everything about every type of customer need.

Getting people to self-identify and disclose conditions remains a challenge. It is therefore unrealistic to expect people to have to repeatedly apply to get on Priority Services Registers, particularly if these only allow one route for communication.

Developing Solutions

Speaker Presentations

The CMA provided an overview of its approach to developing consumer remedies and its ‘remedies universe’ (the range of interventions available for making markets work well for consumers). Examples were then given of the CMA’s markets and mergers work where the businesses involved touched the daily lives of many disabled consumers, or where the projects covered relevant themes, such as the Cygnet/CAS merger (potential purchaser had to demonstrate sufficient care of mental health patients, but standards could be applied to disabled patients in the future). Care homes, Tobi AIU/SSI merger and Pride mobility scooters were further examples.

The presentation moved on to themes for discussion including possible remedies. Monopolistic firms were recognised by the CMA as a key issue with specialisation in segmented markets preventing competitive outcomes. Special attention was paid to performance-based regulation remedies – league tables of businesses based on a set outcome, for example accessibility for disabled consumers – with the example of the Civil Aviation Authority used. The audience were invited to comment on how the technique could be expanded to other sectors, with rail used as a starting point for discussion.

The CMA reflected on its “Access, Assess, Act” framework and how this might be applied to some of the issues facing different disabled groups. Depending on the source of disability, people may find it harder to access the best deals, or to find out about them; if a physical disability affects cognitive capability (for instance, through being tired or in pain) then people might find it harder to assess alternatives and physical constraints may also make it harder to act on decisions. Finally, the CMA closed its section of the presentation with a point on inclusive design, which was fleshed out in the plenary using the audience’s knowledge and expertise.

Plenary Discussion

During the plenary discussion the following points were raised:

• The importance of inclusive design and how it can be used to design products and services so that everyone benefits. One example is writing to a relatively young reading age so that product/service information is accessible. Another example is ramps at zebra crossings which are helpful to cyclists, people pushing buggies or shopping trolleys, as well as people using wheelchairs. It can be cheap to build these designs in from the start but expensive to retrofit.
• Technological developments should be exploited with data leveraged to provide tailored offers that help open-up certain markets for disabled groups (e.g. IBM’s Ask Watson system that has the ability to help disabled people make choices over complex products through comparing product small print).
• Prioritising vulnerability and the needs of vulnerable customer groups should be at the heart of business culture. There are already some good examples of businesses committing to high service levels for different types of disabled customers and working closely with charities and the voluntary sector to ensure that front-line customer service staff are appropriately trained to signpost people to specialist back office support where necessary.
• Businesses must offer multiple channels of communication for disabled customers and recognise that communication needs will vary over time so should offer different channels for keeping in touch. There are some overlaps with other areas of potential vulnerability, such as mental health so it is important to gather information on a customer’s specific needs and keep in touch regularly as these needs may change over time.
• Disabled people should be empowered to develop their own solutions with the potential of collective purchasing being one example of how disabled people might improve their bargaining power and reduce the costs in a market – for e.g. when purchasing assistive technology.

Organisations which attended the roundtable

• Age UK
• Alzheimer’s Society
• Leonard Cheshire Disability
• CLIC Sargent
• Carers UK / Carers Trust
• Disability Rights UK
• Ombudsman Services
• Citizens Advice
• Ofgem
• Ofcom
• FCA
• DCMS
• DWP
• National Aids Trust
• The Equality and Human Rights Commission
• Disabled Persons Transport Advisory Committee
• Research Institute for Disabled Consumers
• The Association of British Insurers
• British Insurers Brokers’ Association
• UK Finance